Rank: Forum user
|
Although I am not involved in the above regulations, I am trying to read them as an area to have a basic knowledge of them. Could anyone tell me how they interact with one another. I understand REACH as covering manufacturing/importing substances over a certain quantity and such a substance has to be regisered with ECHA but this body oversees the CLP regs.
Headache time approaches and I seem to be getting into a mix.
Could anyone try and give me a simple brief so I can use it to aid future reading.
thanks
|
|
|
|
Rank: Super forum user
|
|
|
|
|
Rank: Super forum user
|
To simplify (if I get it wrong please someone tell me):- REACH is for manufacturers of chemicals- if you manufacturer (or import into the EU) you need to register these chemicals under REACH. The definition of chemicals is wide as it does not included just chemicals hazardous to human health but ANY chemical which MIGHT have an effect on human health or the environment. It’s a biggie but it will ( in theory mean that we will have a database describe any chemical which might effect human health or the environment. CLP (which replaces CHIP) describes what information suppliers of chemicals need to give to users of chemicals. It covers both the MSDS (information for which will eventually come from REACH) and labelling on chemicals. The new labels and classifications which will be used under CLP are the ones developed for the Global Harmonisation Standard. Finally COSHH is for employers who use chemicals (and bioagents and other substances hazardous to human health). It requires them to carry out a risk assessment relating to the work that their employees do. MSDS (See CLP) provide a description of the hazards associated with a substance but it is upto he employer to provide a risk assessment for the job/process the chemicals are being used for, using the hazard information for the MSDS( and other appropriate sources). There in 222 words.
|
|
|
|
Rank: Super forum user
|
A Kurdziel wrote:To simplify (if I get it wrong please someone tell me):- REACH is for manufacturers of chemicals- if you manufacturer (or import into the EU) you need to register these chemicals under REACH. The definition of chemicals is wide as it does not included just chemicals hazardous to human health but ANY chemical which MIGHT have an effect on human health or the environment. It’s a biggie but it will ( in theory mean that we will have a database describe any chemical which might effect human health or the environment. CLP (which replaces CHIP) describes what information suppliers of chemicals need to give to users of chemicals. It covers both the MSDS (information for which will eventually come from REACH) and labelling on chemicals. The new labels and classifications which will be used under CLP are the ones developed for the Global Harmonisation Standard. Finally COSHH is for employers who use chemicals (and bioagents and other substances hazardous to human health). It requires them to carry out a risk assessment relating to the work that their employees do. MSDS (See CLP) provide a description of the hazards associated with a substance but it is upto he employer to provide a risk assessment for the job/process the chemicals are being used for, using the hazard information for the MSDS( and other appropriate sources). There in 222 words.
Not bad 9/10 :) I would only adjust that MSDS will be called SDS and a requirement of Manufactures under REACH (they will where appropriate provide scenario specific controls based on downstream use.
|
|
|
|
Rank: Super forum user
|
The end user needs to check that the substance or article they are using is registered on the ECHA website and also that their process/use is notified or listed. Manufacturers and suppliers can (must) refuse to supply if the end users final use is outside their usage scenarios. As an end user you must also keep inventries on all stock affected by REACH. Its a lot of work but its surprising. Even for a reletively small company you have some real opportunities to rationalise stock and reduce inventory. A good overview on REACH can be found on the HSE website; http://www.hse.gov.uk/reach/bitesize.htm
|
|
|
|
Rank: Super forum user
|
John J wrote:The end user needs to check that the substance or article they are using is registered on the ECHA website and also that their process/use is notified or listed.
I thought this only applied when we imported or manufactured more than 1 tonne! John J wrote:Manufacturers and suppliers can (must) refuse to supply if the end users final use is outside their usage scenarios. As an end user you must also keep inventries on all stock affected by REACH. Its a lot of work but its surprising. Even for a reletively small company you have some real opportunities to rationalise stock and reduce inventory. A good overview on REACH can be found on the HSE website; http://www.hse.gov.uk/reach/bitesize.htm I thought exposure scenarios were more like an AcOP - and if there wasn't one you had to fully assess yourself? I don't really see how a manufacture has control over what many smaller downstream user do with a product they buy through a resaler? Just trying to get this clear in my head -REACH always hurts my brain :)
|
|
|
|
Rank: Forum user
|
|
|
|
|
Rank: Super forum user
|
How REACH, CHIP and CLP all interrelate is actually quite complex and there have been various amendments, updates, guidance notes on interpretation, etc. You only have to monitor the Chemical Hazard Communication Society website to see how many queries and uncertainties exist. This society run some extremely good courses on this topic (and others such as safety data sheets, etc.) so I would recommend anyone who wants to know the real picture to take a look at their website (CHCS.org.uk)
Chris
|
|
|
|
Rank: Super forum user
|
Another angle on REACH that is very important to remember (and possibly pertinent to read up on/ keep an eye on if it effects you) are Substances of Very High Concern (SVHC) as identified and the various hoops needed to jump through to get them included/excluded from annex XIV - very broadly, these are generally known carcinogens and the like that current 'users' are having to justify the continued use of moving forward in the balance of benefits to society as a whole v known I'll health effects if not controlled properly. As I look after a plating shop on site you can imagine we have various 'nasties' in baths and some are indeed SVHC. I have just completed our 'returns' for Chromium (VI) trioxide as it was recommended by ECHA for entry into Annex XIV of REACH and am now having to do the same for Cobalt.
If you do indeed use SVHC on-site you really need to at least keep one eye on developments as if they are ultimately excluded from authorisation then a 'sunset date' is applied after which future use will not be allowed - I would hate your business to not be prepared for such a time.
You'll have to do a bit of surfing to satisfy yourselves guys and gals as I'd be writing all day but hopefully the above gives you a flavour to know if you may be effected.
|
|
|
|
Rank: Forum user
|
REACH Is a European Union Regulation. It came into effect on 1st June 2007. It will replace NONS. FAQ on REACH (http://echa.europa.eu/support/faqs/frequently-asked-questions/frequently-asked-questions-about-reach) REACH and COSHH working together info here http://www.hse.gov.uk/coshh/detail/reach.htmCHIP (Chemicals (Hazard Information and Packagnig for Supply) Regs 2009 are being replaced by CLP ( The European – Regulation on Classification, Labelling and Packaging of Substances and Mixtures.) This will come into full effect on 1 June 2015. All the jargon aside check out the links and have a good old read they will probably help. I would explain it all as… REACH is for the manufacturer or importer mostly, of product ‘X’. CLP is for the then classifying, labelling and packaging of the product ‘X’. The new signs that are called GHS (Globally Harmonised Symbols – which are red diamond with a black symbol in it) will replace the old ones ie the black cross on the orange background. The glue that binds it all is still COSHH. There will still need to be a COSHH and (MSDS / SDS from REACH).
|
|
|
|
You cannot post new topics in this forum.
You cannot reply to topics in this forum.
You cannot delete your posts in this forum.
You cannot edit your posts in this forum.
You cannot create polls in this forum.
You cannot vote in polls in this forum.