Newsletter N°3 about the implementation of REACH European Directive in CTS
Update due to the the 13 January 2010 issue of Very High Concern Substances.
A new European Regulations Reach ( 1907/2006/CE Registration, Evaluation Authorisation restriction of Chemicals) has entered in force on 1st of June 2007 .The aim of this new regulation is to improve the awareness about risks that chemicals may have for human health and environment.
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CTS has implemented a working team to ensure that all new requirements which applies to its activities are being implemented.
1 – Following the team work done with our suppliers, we have ensured that all the substances we purchased alone or in preparation have been pre-registered before december 2008.
2 – As down stream user according to Reach definition, we continue to work in close cooperation with our suppliers to ensure the registration of the substances that we are using. This step will continue until 2018 for the additives we are using in very small quantities. This is only at the end of this very long process, that we will get the registration number of all the substances used.
In case of substances will no longer be produced by our suppliers or if during the evaluation phase some dangerous substances will have to be excluded from use, CTS will looked at all alternative solutions for substitution and will keep you informed .
We have asked our suppliers to take into account the uses mentionned in the attached document in the registration dossier. We will keep you informed as soon as possible in case of some uses will not be supported by some of our suppliers to implement the required measures as appropriate.
3 – CTS has implemented a software to edit Safety Data Sheets in conformity with the reach legislation. For preparations and blends that we are producing, the safety Data Sheet is the prefered document for communication down the supply chain of all information as stated by Reach.
In case of presence of Substance of Very High Concern in quantity greater than 0,1%, this situations is clearly mentionned in chapter 15 of the MSDS, as shown on example below.
If changes in the substance classification will occur , those changes will be immediately be made to our safety data sheet.
15 I réglementaires
The list of SVHC will be updated regularly by European autorities. We follow these changes with attention. In case a substance that we are using will enter this list in the future, the MSDS will be updated automatically and you will be informed of the new situation.
We will not issue any certificate or fill questionnaires regarding this point.
4 – DEHP , Cas 117-81-7 is a SVHC which is on the first list of substances to be included in Annex XIV. This substance may be used as plasticiser of somme soft PVC.
This substance can still be used legally except for applications mentionned in regulation CE 552/2009 (annex XVII of REACH) ( toys …) as far as you are telling your customer that the article sold contains DEHP. If by contract, a purchasing ar technical specification from your customer does not allow the use of DEHP, we can supply soft PVC with less than 0.1% DEHP content, including other plasticisers with similar technical performances
New substances SVHC have been added to the
list in January 2010.
CTS used 2 pigments from that list in some rigid
PVC formulations : CI Pigment yellow 34 ( Cas 1344-37-2) and CI Pigment red 104
( Cas 12656-85-8). These pigments can still be used legally, at least until end
of November 2010, but you need to inform your customers of the presence of
these substances in your product ( if the concentration is above 0,1% in mass
).
5 – CLP legislation concerning classification and labelling of substances and blends has entered in force at the end of 2008. This new legislation will be mandatory for the substances by 1 st of December 2010. For compounds which are blends, the actual system will continue to be used untill 1st of june 2015. This is only after this date, that we will implement MSDS according to this new legislation. CLP is the European translation of the GHS system. For country outside Europe, that have already implemented the GHS system, we are already able to issue MSDS according to the GHS system.
Best regards
Hélène HAURY
Product Safety Manager
PJ : IDENTIFIED USES
SECTOR OF USE :
SU12 , CODE NACE 22.2 : Manufacture of plastics products, including compounding and conversion
SU23 , CODE NACE 38 : recycling
PRODUCT CATEGORY :
PC32 : Polymer preparations and compounds.
PROCESS CATEGORY :
PROC5: Mixing or blending in batch processes for formulation of preparations and articles ( multistage and/or significant contact).
PROC8: Transfer of substances or preparations ( charging / discharging) from/to vessels/large containers at non dedicated facilities.
PROC9: Transfer of substances or preparations into small container ' dedicated filling line, including weighing).
PROC12 : Use of blow agents in manufacture of foam industrial setting.
PROC14 : Production of preparations or articles by tabletting, compression, extrusion, peletisation, injection.
PROC21: Low energy manipulation of substances bound in materials and/or articles ( manual cutting, rolling or assembly of material/article, possibly resulting in the release of dust, fibers or fumes.
PROC24 : High mechanical energy work-up of substances bound in materials and/or articles : substantial thermal energy applied to substance by grinding, mechanical cutting, welding, drilling or sanding. Release of solids ( dust) or fumes to be expected .
ARTICLE CATEGORY:
AC1-1 : Passengers cars and motor cycles
AC1-2 : other vehicles : Railway, aircraft, vessels, boats, trucks, and associated transport equipment.
AC2: machinery and mechanical appliances thereof.
AC3-1 : Electrical and electronic products : cables for communication equipments
AC3-3: Electrical and electronic products : household and industry appliances .
AC 12-1: constructional articles and building material for indoor use in plastic.
AC12-2: Constructional articles and building material for outdoor use in plastic.
