The impact of REACH is complex, but not insurmountable.
When the European Union (EU) introduced REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) in 2006 the San Francisco Chronicle called it “the world’s toughest law on toxic chemicals.” For those working in the electronics industry, this doesn’t come as a surprise.
“REACH exists and it is complex,” says Patrice Rollet, general manager of Avantec, performance chemical company based in France. Rollet discussed REACH during his presentation “Global Environmental Regulations—The Next Generation from Europe to China and Back” on Tuesday, April 1, during the 2008 IPC Printed Circuits Expo, APEX and the Designers Summit in Las Vegas.
REACH restricts the use of harmful chemicals and regulates the safe use of chemical transfers from government to industry. It applies to all substances manufactured or imported into the EU in quantities of one tonne or more per year—the greater the tonnage, however, the greater the information required. Hazard assessment, risk assessment, product classification and labeling information are required under REACH.
While the complexities and extensive requirements of REACH may seem insurmountable—especially to the downstream user—Rollet explained that the technical guidance offered by the European Chemicals Agency (ECHA) offers some relief.
“They’re not law,” he says. “But they are official documents.”
Found at http://reach.jrc.it/, the technical guidance documents—of which there are 10—are updated regularly and reflect the need of the downstream user. REACH regulates pure substances, mixes and substances in articles. Rollet points out that, according to REACH, the determination for an article is an item for which shape determines function.
“For example a battery is an article but an ink cartridge is not,” he says. “The substance in the cartridge is in a container.”
Because the regulations affect everyone in the supply chain—manufacturers, importers and their customers—Rollet warns that deciphering REACH is key. Having a game plan is even more important.
“There are risk management measures to take,” he says. “Including implementation of safety data sheets, detailed transmission information and any consolidation information of total formulations.”
Rollet focused his presentation on the obligations and concerns of the downstream user. In addition to examining the guidance documents, as a strategy he reminds downstream users of their obligations, which includes review safety data sheets (SDS); share any pertinent information gleaned from the SDS; give feedback to suppliers if new information should surface; and inform customers if dangerous substances which are candidates for authorization are contained (>0.1%) in the article manufactured or imported.
For more information on REACH, and to access the guidelines, visit the ECHA Web site at http://echa.europa.eu
