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. 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, due to changes such as the introduction of the GHS (Globally Harmonized System of Classification and Labeling of Chemicals) in Europe. Substances in nanostructured form will soon be subject to special regulations under REACH. This poses the ongoing challenge of always implementing requirements by the specified deadline. The ECHA’s scheduled process for evaluating the dossiers already submitted also incurs considerable, additional 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 second transition period expired in late May 2013, and we submitted 67 new dossiers in this second, decisive phase. The key REACH task of registration will occupy us in the coming years considerably beyond the extended registration deadline for phase-in substances in 2018 – after all, registration is not completed just because a dossier has been submitted to ECHA. Based on the ECHA timetable, postprocessing will take up several years beyond the submission deadlines.
Registration also indirectly impacts polymers, although polymers themselves are exempt from registration and evaluation. All monomeric components and chemically bonded additives that constitute 2% or more of a polymer must be registered.
Intensive Dialog with our Customers and Suppliers
REACH continues to demand close communication between producers, importers and users regarding the use of a substance. This ensures that all are aware of any potential risks and possibilities of exposure (for humans and the environment), and of the proper steps to take to protect humans and the environment. Any substance produced or imported in quantities of over 10 metric tons per year must be carefully analyzed according to the safety stipulations in 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.
We therefore actively seek dialog with our business partners 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.
The MSDS: a Source of Information on Applications and Risk Management
WACKER ensures that, if used correctly, no risk to health or the environment is posed by any of its products. We continually update our product information and constantly revise our risk assessments to take account of new findings.
Our material safety data sheets explain what steps 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 material safety data sheets are updated as soon as safety assessments and substance safety reports have been compiled for registration. WACKER provides material safety data sheets for all of its sales products, regardless of legal requirements. In total, we make over 75,000 material safety data sheets available in up to 35 languages.