Implementing REACH: WACKER is on schedule
WACKER has been heavily involved with the REACH regulation ever since the EU Commission issued its white paper on chemicals policy in 2001
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We have carefully monitored developments in European chemicals legislation, and striven for a workable implementation of the directive in detail. In parallel with development of the REACH legislation, we regularly analyzed what effect this legislation would have on our company and products, and implemented the necessary internal changes. REACH is continually subject to modification, e.g. due to the introduction of the GHS (Globally Harmonized System of Classification and Labelling of Chemicals) in Europe. This means that we are permanently obliged to carry out implementation of the changed requirements within the specified period. The ECHA's scheduled process for evaluating the dossiers already submitted also incurs additional, considerable expense, both for the authority itself, and for the companies involved.
A determined push to implement the new EU legislation
At WACKER, we naturally view compliance with the new EU legislation as an integral part of our comprehensive risk management policy and our preventative approach to protecting the environment and ensuring public safety. In accordance with REACH deadlines, phase-in substances were preregistered in 2008. This chiefly included previous "legacy substances" listed in the European Inventory of Existing Commercial Chemical Substances (EINECS) as well as substances that were manufactured at least once in the 15 years before REACH came into force, but were never placed on the market. We pre-registered all substances relevant for our products at the European Chemicals Agency. In so doing, we met the December 1, 2008 deadline for completing the first step of REACH implementation.
The first major hurdle of the REACH regulation was the first deadline for the registration of phase-in substances, which expired on December 1, 2010. This applied above all to the phase-in substances that a company manufactures or imports in quantities of over 1,000 metric tons per year. WACKER submitted 85 registration dossiers on this date. The next transition period expires mid 2013, and we plan to submit 67 dossiers in this second, decisive phase. The key REACH task of registration will occupy us in the coming years considerably longer than the extended registration deadline for phase-in substances in 2018 – for registration is not completed just because a dossier has been submitted to ECHA. Postprocessing at the ECHA can take several years.
Registration also indirectly impacts on polymers, although polymers themselves are exempt from registration and evaluation. All monomeric components and chemically bonded additives that constitute 2% (w/w) or more of a polymer must be registered.
Intensive dialog with our customers and suppliers
REACH demands close communication between producers, importers and users with regard to a substance's use to ensure that all are aware of any potential risks and possibilities of exposure (for humans and the environment), as well as the proper measures for protecting humans and the environment. If produced or imported in quantities of over 10 metric tons per year, a substance's safety must be carefully analyzed in accordance with Annex I of the REACH legislation. An assessment of possible exposure and a risk analysis must be performed for all hazardous substances from this annual quantity upwards.
Therefore we actively seek dialog with our suppliers in order to ensure compliance with REACH provisions. Exchanging detailed data with our customers and suppliers on uses and exposure is particularly useful and indeed necessary when we have identified a need for further information during evaluation of our own substance safety findings.
Material safety data sheets give details of the applications and risk containment
WACKER ensures that all its products, if used properly, pose no risk to humans or the environment. We continually update our product information and constantly revise our risk assessments to take account of new findings.
Our Safety Data Sheets explain what measures should be taken to contain risk when using our products, insofar as these contain hazardous substances. To promote the use of our products in a wide range of applications, our product descriptions use exposure scenarios that can apply to a variety of uses. Existing Safety Data Sheets are updated as soon as safety assessments and substance safety reports have been compiled for registration. WACKER provides Safety Data Sheets for all its sales products, regardless of legal requirements. In total, we make over 50,000 Safety Data Sheets available – in up to 33 languages.
