REACH FAQ
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Appendix 1: Panel Discussion
Notes: EIF = Entry into Force; GHS = Globally Harmonised System
General
Q1: How will scrap recycling be handled under REACH?
A1: scrap is waste unless a substance is recovered, when it becomes a DU. Recovery of substances must be covered by the ES, recycling as an intended use.
Q2: will REACH promote better MSDS sheets?
A2: Yes, not least because under REACH the SDS has to be complete.
SDS may need to be revised after EIF of the European GHS Regulation expected 2nd half of 2007.
Q3: If M/I does not agree to include our use in his Registration dossier, do we have to register?
A3: this is covered by Art 37/4. Under this the DU has to provide a CSR.
Q4: what obligation has a M/I when registering a substance not sold today but may use in the future? Could a M/I register after the registration period?
A4: it is advisable to pre-register substances in products being researched. Under Art 9 substances required for research can be M/I without registration for up to 5 years with possible extension for a further 5 years.
Q5: how do I know if my supplier has Pre-Registered?
A5: Art 28/4 states that the public list of substances Pre-Registered will NOT include details of manufacturers.
REACH and PM substances
Q1: when could Nickel disappear from the market?
A1: if new tests cause Nickel to be reclassified as high toxicity it could be subject to authorisation. In this event its use could be restricted or even banned. Restriction does however allow for socio-economic arguments to be used in support of retention.
REACH and other chemicals
Q1: are lubricants like waxes or stearates polymers and therefore exempt?
A1: it will be advisable to ask your supplier if the preparation contains polymers. Q2: how will oil filled bearings be handled under REACH? And Brake pads?
A2: articles are exempt unless they emit hazardous substances during normal handling and use. It will be necessary to evaluate the substances emitted.
Q3: How should process gas be considered under REACH?
A3: If not chemically modified, process gas and components thereof are exempt from Registration (Art 2.7.b, Annex V.7) and other obligations under REACH. However they may be subject to Authorization.
Q4 : How should Endogas be considered under REACH?
A4: Endothermic gas (Endogas) is a blend of carbon monoxide, hydrogen, and nitrogen (with smaller amounts of carbon dioxide water vapor, and methane) produced by reacting a hydrocarbon gas such as natural, gas (primarily methane), propane or butane with air. Following chemical reactions between the constituents and during the process new substances are produced (principally carbon monoxide). These are probably non-isolated intermediates (Art 3.15) and therefore exempt from REACH (Art 2.1.c). REACH and communication
Q1: what sort of questionnaire should I send to my customers?
A1: the EPMA can help powder makers to agree on a single common industry template. The EPMA provides in another section the letters for the suppliers and a supplier obligation text to be included in a purchase contract.
Uses and articles
Q1: is the list of 4 generic identified uses "official" or is it merely an EPMA proposal
A1: this is Höganäs AB suggestion only, Höganäs would welcome comments.
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