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

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

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!

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

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.

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.

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.

Metal dusts are a particular class of combustible dusts as they encompass a large family of energetic materials with diverse explosion sensitivity and severity properties. Specifically, metal dusts exhibit higher (adiabatic) flame temperatures than organic dusts, but either lower or higher maximum explosion pressures (Pmax) and deflagration indexes depending on the reactivity of the metal involved, the particle size distribution and the presence of an oxide film. They can be segregated as normally reactive (e.g. iron, steel, zinc), highly reactive (e.g. silicon), or extremely reactive (e.g. aluminium and magnesium), with a corresponding hazard class ranging from St1 to St3. In addition to be more reactive, fine metallic particles can be very sensitive to ignition sources (i.e. require very low amount of energy to ignite and start burning). Ultrafine particles (< 1 µm) can even be pyrophoric, i.e. they spontaneously burn when in contact with the air. Fine particles of aluminum, for example, can exhibit high KSt (> 300 bar.m/s) and Pmax (> 10 bar) values corresponding to a St3 classification, and low minimum ignition energy (MIE < 10 mJ), making difficult the prevention and mitigation of such deflagrations....

…but are they supplying stainless steel dust (or nano particles) or stainless steel components which won’t catch fire. Remember anything will catch fire if you apply enough heat (plasma torch?) and oxygen.  If REACH means that something made of stainless steel needs to be certified(?) then just about any object needs an SDS. Not what the regs were intended for.

Thanks

What has this to do with H&S? The link explains how different metals and alloys are classified for I assume tariff purposes not safety matters.