REACH Intertek Group PLC July 2009 By Ms. Sunanda Kadam 1 - - PowerPoint PPT Presentation

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REACH Intertek Group PLC July 2009 By Ms. Sunanda Kadam 1 - - PowerPoint PPT Presentation

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REACH Intertek Group PLC July 2009 By Ms. Sunanda Kadam 1 Intertek REACH Presentation, May 2007 www.intertek.com 2009 About Intertek Global leader in Testing. Inspections and Certifications We support our customers in their global

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Intertek REACH Presentation, May 2007 1 www.intertek.com

Intertek Group PLC July 2009 By Ms. Sunanda Kadam

REACH

2009

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Intertek REACH Presentation, May 2007 2 www.intertek.com

About Intertek

  • Global leader in Testing. Inspections and Certifications
  • We support our customers in their global and local trade
  • We provide quality, environmental and safety services for

a wide range of products, commodities and industries

  • Outsourcing these services to Intertek brings increased

value to customers’ products and processes

  • Allows our customers to focus on their core business and

processes

  • Website : www.intertek.com

2009

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Intertek REACH Presentation, May 2007 3 www.intertek.com

The industries we operate in

Agriculture Automotive Chemical Consumer Products Electrical & Electronic Energy & Fuels Food Government Industrial IT & Telecom Minerals Pharmaceutical Retailers

Our organisation

CONSUMER GOODS COMMERCIAL & ELECTRICAL INDUSTRIAL OIL, CHEMICAL, AGRI & Minerals GOVERNMENT

Supporting our customers in their global trade…..

What we do Testing Inspection Certification Auditing Quality Assurance Advisory

Our industries

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Intertek REACH Presentation, May 2007 4 www.intertek.com

An extensive global network

– Laboratories > 450 – Offices > 630 – People > 26,000 – Countries > 110

  • Competitive know-how for our

customers in diverse markets

  • FTSE 250
  • Market capitalisation at £1.5bn

2009

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Intertek REACH Presentation, May 2007

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REACH and Article Details

Substances of Very High Concern

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Intertek REACH Presentation, May 2007 6 www.intertek.com

Definitions of Articles

Article : An object which during production is given a special shape, surface or design which determines its function to a greater degree than does its chemical composition.

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Intertek REACH Presentation, May 2007 7 www.intertek.com 2009

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Intertek REACH Presentation, May 2007 8 www.intertek.com

Definition

  • Substance of Very High Concern (SVHC)

– CMR: Carcinogenic, mutagenic and toxic for reproduction – PBT : Persistent, Bioaccumulative and Toxic – vPvB: very Persistent and very Bioaccumulative substances – Similar substances, e.g. endocrine disrupter

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Intertek REACH Presentation, May 2007 9 www.intertek.com

15 SVHC published in October

  • Anthracene
  • 4,4’-Diaminodiphenylmethane
  • Dibutyl phthalate (DBP)
  • Cobalt dichloride
  • Diarsenic pentaoxide
  • Diarsenic trioxide
  • Sodium dichromate
  • 5-tert-butyl-2,4,6-trinitro-m-xylene

(musk xylene)

  • Bis (2-ethyl(hexyl)phthalate)

(DEHP)

  • Hexabromocyclododecane

(HBCDD) and all major diastereoisomers identified (α- HBCDD, β-HBCDD, γ-HBCDD)

  • Alkanes, C10-13, chloro (Short

Chain Chlorinated Paraffins)

  • Bis(tributyltin)oxide
  • Lead hydrogen arsenate
  • Triethyl arsenate
  • Benzyl butyl phthalate (BBP)

http://echa.europa.eu/chem_data/candidate_list_table_en.asp

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Intertek REACH Presentation, May 2007 10 www.intertek.com

SVHC Basics

  • SVHC = Substance of Very High Concern
  • REACH Definition

– Substances on the candidate list for authorisation

  • Details

– Additional responsibilities for preparations and articles containing >0.1% w/w of an SVHC substance – SVHC need to be identified in MSDS documents – Articles

  • Legal obligations of Article 33 and Article 7(2)
  • Communication obligations
  • Notification obligations
  • Plus industry related obligations (outside of regulation)

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Intertek REACH Presentation, May 2007 11 www.intertek.com

Duty to communicate down supply chain - Article 33

Consumers may request information about presence of SVHC in articles (must reply within 45 days)

Apply to ALL articles If SVHC present >0.1% Inform customers minimum

  • Chemical Name
  • Information on safe use

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Intertek REACH Presentation, May 2007 12 www.intertek.com

Sample Letter Suggested by NGO

Date Dear Sir/Madam In accordance with the new European regulation on Chemicals, REACH, I am writing to ask you to inform me about the presence in the product XX or its packaging of any chemical from the group of "substances of very high concern" as specified by REACH. Should any of these substances be present in the product XX or its packaging, I wish to be informed about the name of this substance, and receive sufficient information on how I can protect myself and the environment from it. I would be grateful to receive this information within 45 days as required by REACH. I would be grateful if you would inform me about steps you are taking to provide products intended for the same use but which do not contain such potentially hazardous chemicals. Yours faithfully, cc: European Chemicals Agency - P.O. Box 400, 00120 Helsinki, Finland, phone: +358-9-686180 e-mail: info@echa.europa.eu, www.echa.europa.eu

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Intertek REACH Presentation, May 2007 13 www.intertek.com

Notification for Articles

  • If SVHC present in Article > 0.1% & amount of SVHC > 1

tonne/year, Notification is required.

  • Volume is sum up of all products
  • Time Frame:

SVHC before Dec 2010: by 1 Jun 2011 SVHC after Dec 2010: within 6 months after the inclusion

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Intertek REACH Presentation, May 2007 14 www.intertek.com

REACH Services - Intertek www.intertek.com/reach

Data Gathering and Analysis

Product-level data

Identify Products Classify Products Substance Preparation Article Substance Data Collection Possible Notification Intended Release? Substance Concentrations Substance Data Collection Substance Data Collection No Further Requirements

Yes No

Contain SVHCs?

Yes

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Intertek REACH Presentation, May 2007 15 www.intertek.com

SVHC – Example Approach Consumer good Industries

  • Uniform approach adopted by European Buyers
  • Includes

– Common letter to suppliers – Common REACH questionnaire to suppliers – Common schedule and deadlines

  • SVHC commitment (to be signed by supplier)

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Intertek REACH Presentation, May 2007 16 www.intertek.com

Pre-Registration

Substances in Preparation Substances intended to be released from articles

Requirement of SVHC

SVHC in articles > 0.1% (w/w) Notification Informing recipients

Registration within the grace period

>1t/y ?

Requirement Summary

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Intertek REACH Presentation, May 2007 17 www.intertek.com 2009

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Intertek REACH Presentation, May 2007 18 www.intertek.com

Communication in supply chain

  • Industry need to improve the communication through

its supply chain

  • Suppliers have to assist to provide information on

substances

  • Safety information communicated also to the

downstream users & distributors

  • Information include health, safety & environmental

properties, risks, risk management measures

  • Primary tool – Safety Data Sheet (SDS) based on

identified uses

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Intertek REACH Presentation, May 2007 19 www.intertek.com

Supplier Declaration

  • Difficult to demonstrate that supplier has the knowledge – too

many SVHC

  • Likely to fail on supplier audit
  • NOT a means to demonstrate due diligence
  • Use in combination of chemical analysis if necessary, e.g. XRF or

GC-MS screening

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Intertek REACH Presentation, May 2007 20 www.intertek.com

Authorization Requirement for SVHC

Ensure risks from SVHC are properly controlled or substituted

  • SVHC only, ~1500 substances
  • Applicant to show:

– Adequate control of risks, or – Social and economic benefits outweigh the risks (no substitution)

  • Applicant requires to analyse

alternatives

Substance authorised under adequate controls

Substitute No safe use or no threshold limit Safe use No benefits Benefits Chemicals of High Concern Use substitute No authorisation Substance authorised when benefits

  • utweigh risks

No substitute Periodic review/Analysis of alternatives

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Intertek REACH Presentation, May 2007 21 www.intertek.com

How we can help…

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  • Chemicals

– Product assessment and data gathering – Only Representative – Pre-registration – Dossier Creation – Registration – Testing – Supplier auditing

  • Products

– Product assessment and data gathering – SVHC (Substance of Very High Concern) Declaration – Product Testing – Supplier auditing

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Intertek REACH Presentation, May 2007 22 www.intertek.com

REACH SVHC Assessment

– Determine Client’s REACH requirements detailing

  • Companywide responsibilities
  • Product-level responsibilities

– Determine Client’s REACH position (i.e. manufacturer, importer, DU, formulator, etc)

  • Recommendation on EU status

– Can Client take responsibility? – Should Client take responsibility? – Review against definition of Articles

  • Determine risk of intentional release of substances

– Review candidate list of SVHCs

  • Review Product Information provided by Client
  • Assess areas of risk for SVHC substances

– Prepare Client REACH Positional Statement – Determine dates/deadlines for product responsibilities

  • Assess long-term requirements such as Authorizations and possible

Restrictions – Overview responsibilities within the supply chain – Strategy Guide and plan for SVHC Compliance

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Intertek REACH Presentation, May 2007 23 www.intertek.com

REACH SVHC Testing

  • Processing of product to create uniform sample for

laboratory testing

  • Laboratory testing and screening for SVHC chemicals

applicable to product

  • Testing report
  • Assessment report

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Intertek REACH Presentation, May 2007 24 www.intertek.com

REACH Certificate

  • Product Checklist Review

– Review of client information against checklist requirements of either articles, preparations, or substances – Corrective action report issued if additional compliance steps are required

  • Creation of REACH Compliance Certificate

– REACH Compliance Certificate issued to client for product/ substance based on all REACH requirements being met – Contact information for Intertek REACH team for Client customer verification of basis of compliance

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Intertek REACH Presentation, May 2007 25 www.intertek.com

Contact Us:

Websites:

  • http://www.intertek.com/reach/

Solutions: Sunanda Kadam: sunanda.kadam@intertek.com Address:

Intertek India Pvt Ltd Unit No.D1,Udyog Sadan No.3, MIDC Central Road, Andheri ( East), Mumbai 400093, India. PH : 91-22-28244767 Ext : 110 FAX :91-22-28244768 Mobile : 91-9920061911

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Intertek REACH Presentation, May 2007 26 www.intertek.comQ & A 2009