Life Cycle Thinking Blog Moves

Life Cycle Thinking blog is moving.

I will continue to provide commentary about TSCA, REACH, product stewardship, sustainability, environmental marketing claims and more as part of the redesigned EHS Strategies, Inc. website.

Georjean Adams

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REACH Registration Due May 31, 2013

ECHA reminds submitters to get in early for the second round of REACH applicable to manufacture or import  between 100 – 1,000 metric tonnes/yr of a chemical substance not previously registered.  The official deadline is May 31, but since many dossiers have been incomplete in the past, lead registrants are strongly advised to get their dossier in by March 31.

Reminder: Imported articles are exempt unless intended to release a chemical substance.  (Notification, not registration, and customer communication can be triggered, regardless of volume, for articles with >0.1% Substances of Very High Concern.)

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REACH Authorization Proposed for 10 SVHC

ECHA has recommended 10 Substances of Very High Concern to go onto the Authorization list.  Once finalized by the European Commission, Member States and EU Parliament, sunset (ban) dates will be set and companies will need to file and get authorization for use approved to continue marketing past those dates.  The proposed chemicals and their typical uses:

#	Substance name and SVHC property	Uses in the scope of authorisation (examples)
1	Formaldehyde, oligomeric reaction products with aniline (technical MDA) (carcinogenic)	Hardener for epoxy resins; curing agent for polymers
2	Arsenic acid (carcinogenic)	Used to modify properties of glass and in the production of printed circuit boards
3	Dichromium tris(chromate) (carcinogenic)	Anti-corrosion surface treatments of steel and aluminium in the construction and the aeronautic sectors
4	Strontium chromate (carcinogenic)	Anti-corrosion coatings in the aeronautic/aerospace, coil coating and vehicle coating sectors
5	Potassium hydroxyoctaoxodi­zincatedichromate (carcinogenic)	Anti-corrosion coatings in the aeronautic/aerospace and vehicle coating sectors
6	Pentazinc chromate octahydroxide (carcinogenic)	Anti-corrosion coatings in the vehicle coating and the aeronautic/aerospace sectors
7	Bis(2-methoxyethyl) ether (Diglyme) (toxic for reproduction)	Primarily used as a reaction solvent or process chemical in distillation applications; further in batteries and in the production of plastics
8	N,N-dimethylacetamide (DMAC) (toxic for reproduction)	Solvent in synthesis, the production of synthetic fibres, in industrial coatings, paint strippers, insulation paper, films and membranes
9	1,2-dichloroethane (EDC) (carcinogenic)	Solvent in the manufacture of fine chemicals and pharmaceuticals and in mixtures for biochemical applications
10	2,2′-dichloro-4,4′-methylenedianiline (MOCA) (carcinogenic)	Curing agent in resins and in the production of polymer articles

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138 SVHC Now

There are now 138 Substances of Very High Concern under REACH with the addition of another set of 54 chemicals December 19, 2012.  Producers and importers of articles have 6 months to notify ECHA if articles contain more than 0..1% by weight and the use hasn’t already been registered.

Companies need to keep on top of new listings (about every 6 months) and be prepared to find out whether articles you make, sell or buy contain >0.1% adding to more than 1 metric tonne/yr.  You can also see what’s likely to come up by looking at the list of “intentions” to add to the Candidate list here.

Also track whether any of the chemicals reach the “Authorization” (14 so far) stage that will restrict use.

EHS Strategies, Inc. can help you with the implications for your company.

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REACH Reality

Pointed comments by outgoing CEFIC (European Chemical Industry Council) president Squinzi on REACH here.  One highlight on the 2 billion euro cost since 2007:

“This is within the initial cost range for the whole of REACH, yet we have only passed through the first registration deadline. This points to two things: firstly, the costs are high; secondly, as smaller organizations enter the REACH processes we must find ways to eliminate all unnecessary costs. This can range from highlighting the big cost items and amending the legislation to simplifying the procedures at the implementation phase. Here, we look to the agency to review any activities which we’re not explicitly required by the legal text.”

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REACH Evaluation

Helpful webinar slides and audio have been posted on ECHA’s site regarding the CoRAP evaluation process on chemicals registered under REACH.

Presentations emphasize the tight time frame for the evaluations and the need to coordinate with fellow registrants so you have a central contact point (likely the lead registrant) to deal with issues around new testing and data submissions that may be raised by the evaluating member state.  ECHA speakers reminded people that the listing on CoRAP does not mean there will be any change in current regulation of the chemical.  Of course, time will tell.

List of current (90) CoRAP chemicals

See earlier blog here

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REACH Ambitious SVHC Intentions

Whew!  Make that 54 more chemicals ECHA is looking to add to the Substances of Very High Concern (SVHC) here.  See if your favorite is on the list and comment if you want by October 18.

Phthalates, nonylphenols, a bunch of lead compounds, propylene oxide, TDA and more….

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REACH Intentions

For those of you who like to get ahead of official listings under REACH, ECHA has a posting of “intentions” to list new SVHC Candidates, proposed restrictions and classification and labeling harmonization proposals: http://echa.europa.eu/web/guest/addressing-chemicals-of-concern/registry-of-intentions

Also be aware that there’s also a push to really up the number of SVHC by the end of the year (to 136 from the current 84).

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REACH Registrations Count

ECHA’s Registered Substances Database contains 7,530 unique substances with information from over 30,000 dossiers.

A little under 3,000 chemicals have been identified as “intended” to be registered with the next deadline of May 31, 2013, for chemicals in the 100 – 1000 metric tonnes range.

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REACH Authorization: 10 Closer Chemicals

ECHA is taking comments on the next batch of chemicals likely to be subject to authorization:

1. formaldehyde, oligomeric reaction products with aniline (technical MDA)
2. arsenic acid
3. dichromium tris(chromate)
4. strontium chromate
5. potassium hydroxyoctaoxodizincatedichromate
6. pentazinc chromate octahydroxide
7. bis(2-methoxyethyl) ether (diglyme)
8. N,N-dimethylacetamide (DMAC)
9. 1,2-dichloroethane (EDC)
10. 2,2′-dichloro-4,4′-methylenedianiline (MOCA)

On the other hand, the following phthalates are not going to be further restricted for use in articles than they already are: DEHP, DBP, BBP, and DIBP   ECHA notice

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