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ianjones  
#1 Posted : 13 January 2021 09:11:30(UTC)
Rank: Forum user
ianjones

Good monring all

Previous under Reach we issued a in house certificate stating that we met the reqiurements of Reach

is this sufficient under UK Reach or do i need to do anything else?

Alan Haynes  
#2 Posted : 13 January 2021 10:13:11(UTC)
Rank: Super forum user
Alan Haynes

Talk to HM Customs people.
John Murray  
#3 Posted : 13 January 2021 10:13:53(UTC)
Rank: Forum user
John Murray

https://www.hse.gov.uk/reach/brexit.htm

Kate  
#4 Posted : 13 January 2021 10:18:30(UTC)
Rank: Super forum user
Kate

I'm baffled - what does REACH have to do with stainless steel parts?

thanks 1 user thanked Kate for this useful post.
A Kurdziel on 13/01/2021(UTC)
Roundtuit  
#5 Posted : 13 January 2021 11:37:45(UTC)
Rank: Super forum user
Roundtuit

Some forms of Stainless Steel as articles may necessitate communication duties e.g. for candidate SVHC's (Substances of Very High Concern) and notification duties e.g. to the SCIP (Substances Contained in Products) database.

What would need clarification by the OP is what this original "certificate" contained - many early examples merely stated the substances had been pre-registered or registered as required and carried a comment regarding the presence of any candidate SVHC >0.1% w/w.

Whilst EU and UK REACH are tightly aligned at present there are now some differences appearing e.g. under UK REACH there is no pre-registration, notification to the UK Poison Centre is voluntary (as is the generation of a UFI - Unique Formula Identifier), UK Down Stream Users of EU sourced products are now classed as importers, UK manufacturers who do not ship products to Europe do not need to make SCIP notifications.

The HSE ran a series of webinars on 16th December 2020 - recordings are available on their Video Platform channel. A follow up session is taking place on 20th January 2021

https://hse-chemicals-brexit.co.uk/home?utm_source=govdelivery&utm_medium=email&utm_campaign=EU-Exit-hse&utm_term=follow-up-event&utm_content=chemicals-23-dec-20

thanks 2 users thanked Roundtuit for this useful post.
Kate on 13/01/2021(UTC), Kate on 13/01/2021(UTC)
Roundtuit  
#6 Posted : 13 January 2021 11:37:45(UTC)
Rank: Super forum user
Roundtuit

Some forms of Stainless Steel as articles may necessitate communication duties e.g. for candidate SVHC's (Substances of Very High Concern) and notification duties e.g. to the SCIP (Substances Contained in Products) database.

What would need clarification by the OP is what this original "certificate" contained - many early examples merely stated the substances had been pre-registered or registered as required and carried a comment regarding the presence of any candidate SVHC >0.1% w/w.

Whilst EU and UK REACH are tightly aligned at present there are now some differences appearing e.g. under UK REACH there is no pre-registration, notification to the UK Poison Centre is voluntary (as is the generation of a UFI - Unique Formula Identifier), UK Down Stream Users of EU sourced products are now classed as importers, UK manufacturers who do not ship products to Europe do not need to make SCIP notifications.

The HSE ran a series of webinars on 16th December 2020 - recordings are available on their Video Platform channel. A follow up session is taking place on 20th January 2021

https://hse-chemicals-brexit.co.uk/home?utm_source=govdelivery&utm_medium=email&utm_campaign=EU-Exit-hse&utm_term=follow-up-event&utm_content=chemicals-23-dec-20

thanks 2 users thanked Roundtuit for this useful post.
Kate on 13/01/2021(UTC), Kate on 13/01/2021(UTC)
stevedm  
#7 Posted : 17 January 2021 11:19:37(UTC)
Rank: Super forum user
stevedm

if you bob over to the ECHA website and search for Steel you will find all the Information for the current list...

https://echa.europa.eu/search-for-chemicals

A Kurdziel  
#8 Posted : 18 January 2021 09:36:39(UTC)
Rank: Super forum user
A Kurdziel

Out of  stupid curiosity I did look at the ECHA website and this is what it said about “Steel”- “ Hazard classification & labelling -According to the majority of notifications provided by companies to ECHA in CLP notifications no hazards have been classified.” A bit like Hitchhiker’s Guide To the Galaxy’s classification of earth. Not really surprising!

Roundtuit  
#9 Posted : 18 January 2021 10:21:41(UTC)
Rank: Super forum user
Roundtuit

Three "named" entries for Stainless Steel including EC 912-49-00 classified as Flammable Solid, Eye Irritant.

Roundtuit  
#10 Posted : 18 January 2021 10:21:41(UTC)
Rank: Super forum user
Roundtuit

Three "named" entries for Stainless Steel including EC 912-49-00 classified as Flammable Solid, Eye Irritant.

ianjones  
#11 Posted : 20 January 2021 14:14:09(UTC)
Rank: Forum user
ianjones

The purpose of the post is that i have to issue a REACH certificate to multiple car companies saygin we conform to eU and UK REach rules and we are struggling as it is a very complex area

Roundtuit  
#12 Posted : 20 January 2021 16:34:48(UTC)
Rank: Super forum user
Roundtuit

Appreciating your frustration would you care to enlighten us as to which regulation(s) and article(s) this certficate is being prepared to answer as a search of the REACH legal text for "certificate" reveals four references to aviation and one to training with paint stripper.

Roundtuit  
#13 Posted : 20 January 2021 16:34:48(UTC)
Rank: Super forum user
Roundtuit

Appreciating your frustration would you care to enlighten us as to which regulation(s) and article(s) this certficate is being prepared to answer as a search of the REACH legal text for "certificate" reveals four references to aviation and one to training with paint stripper.

Ian Bell2  
#14 Posted : 20 January 2021 18:32:38(UTC)
Rank: Super forum user
Ian Bell2

Please can you outline how stainless steel is considered to be a flammable solid. We recently commissioned some material testing via a laboratory for explosive/combustible properties of plain carbon steel and stainless steel for the purposes of DSEAR assessment. Unsurprisingly the tests returned a result that steel (either type) is not flammable or explosive.

In 30 yrs of being involved with mechanical engineering - and associated materials science, I can recall no text book or source of engineering material data that has ever indicated that stainless steel (even as a dust) poses any explosion or flammability hazard.

There is no mention of stainless being an explosive/flammability risk on the HSE website or in HSG103 Safe handling of combustible dusts.

Roundtuit  
#15 Posted : 20 January 2021 19:07:00(UTC)
Rank: Super forum user
Roundtuit

Please refer to the ECHA web site where a pre-registration applied the classification to an entry made against the IUPAC name "Stainless Steel".

It was worthy of flagging beacuse it is so blatantly wrong.

Roundtuit  
#16 Posted : 20 January 2021 19:07:00(UTC)
Rank: Super forum user
Roundtuit

Please refer to the ECHA web site where a pre-registration applied the classification to an entry made against the IUPAC name "Stainless Steel".

It was worthy of flagging beacuse it is so blatantly wrong.

Ron Hunter  
#17 Posted : 21 January 2021 16:06:46(UTC)
Rank: Super forum user
Ron Hunter

Thought I'd posted here but lost it. Apologies if the gist of this turns up later.

Get the MD to sign a fancy certificate saying not applicable for the purposes of REACH, specified item is not and does not constitute a chemical, substance or mixture.

List the relevant standard for the stock material for reference.

Beware of passivation or plating finishes though! e.g. Cadmium Plate is a no-no in several European Countries.

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