Filed under: EU Regulation/Legislation, REACH/CLP, Toys | Tags: lead, REACH, regulation
The European Commission has adopted a new restriction under the REACH Regulation which covers lead in consumer items which “during normal or reasonably foreseeable conditions of use, be placed in the mouth by children.”
The Regulation, 2015/628, restricts the placing on the market of consumer items containing 0.05 % lead, by weight, overall or in those parts accessible to children unless it can be demonstrated that the rate of lead release from such an article or any such accessible part of an article, whether coated or uncoated, does not exceed 0.05 μg/cm2 per hour (equivalent to 0.05 μg/g/h), and, for coated articles, that the coating is sufficient to ensure that this release rate is not exceeded for a period of at least two years of normal or reasonably foreseeable conditions of use of the article.
Enforcement of this Regulation depends upon the more subjective assessment of whether normal conditions of use would endanger children by the placing of the items in the mouth, as well as the more objective measurement of the lead content, which should not prove a significant issue for any competent laboratory accredited for such tests.
Filed under: chemicals, ECHA, REACH/CLP | Tags: chemicals, CLP; REACH; Chemicals; ECHA, REACH
The plan details that 134 substances are due to be evaluated by Member States over the 2015-17 period, with 48 alone being evaluated this year. These substances have a suspicion that their manufacture and/or use could pose risks to human health and/or the environment. Some of the more common substances being evaluated across various Member States in 2015 are:
- aluminium chloride
- octamethyltrisiloxane, decamethyltetrasiloxane and dodecamethylpenta- siloxane , all suspected by the UK authorities of being persistent, bioaccumulative and toxic (PBT) substances.
Filed under: chemicals, ECHA, EU Information, REACH/CLP | Tags: CLP; REACH; Chemicals; ECHA, SVHCs
The Advocate General to the European Court of Justice, a senior legal advisor, has issued a ruling stating that companies (manufacturers and importers) have an obligation under REACH to report the presence of substances of very high concern (SVHCs) in articles and this applies to all components incorporated into articles, not the whole article. REACH Article 33 states that companies must inform the European Chemicals Agency (ECHA) if an SVHC is present, totalling over one tonne per producer or importer per year, in a concentration higher than 0.1 % by weight.
A number of member states have considered that the obligations under REACH for companies only applied to the whole (e.g. finished) article. A good example of this would be a car, where SVHCs may be found in some specific components at appropriate concentrations, but overall would be significantly lower.
This means that companies in all member states will need to ascertain the levels of SVHCs in all components used in the assembly of any product, which will require a greater breadth of analytical testing in many cases.
The European Chemicals Agency (ECHA) has agreed the first steps of a new approach to improve the completeness check of incoming REACH registrations. It aims to reinforce the automatic completeness check rules on substance identity (SID) information, and will request the identification of the scope of joint registrations with regard to SID information.
This recognises the importance of accurate substance identity data, and the correct and consistent naming of chemical compounds registered under REACH. ECHA wants to work in tandem with the REACH SIDC project, which covers the analysis of substance identity and substance sameness of complex substances in REACH. It is organising a workshop to be held in Brussels on 27-28 April 2015, to which any organisation with an interest in this should attend.
It is very important for companies registering substances under REACH to be able to carry out, or draw on, validated analytical techniques to properly identify a substance, or determine the composition of mixtures and complex substances.
Filed under: chemicals, REACH/CLP, transport, UK Legislation | Tags: Biocides, chemicals, CLP, Health & Safety
An amendment to the existing UK legislation covering the Classification, Labelling and Packaging of chemicals has been published. The Classification, Labelling and Packaging of Chemicals (Amendments to Secondary Legislation) Regulations 2015 (SI 21) has a wide-reaching effect.
This new SI fully implements Regulation EC 1272/2008 (the CLP Regulation), and takes into account the number of other Directives which are affected by CLP legislation in the EU. They also amend the provisions as they apply to merchant shipping, and apply UK-wide. They also amend the UK REACH legislation (S.I. 2008/2852; amended by S.I. 2009/238 (Northern Ireland) and S.I. 2009/716), adding a new sub-paragraph (1ka) in Part 1 of Schedule 3 to give the definition of a hazardous substance or mixture in line with CLP regulations.
The Chemicals (Hazard Information and Packaging for Supply) Regulations 2009 (known as CHIP), which implemented Directives 67/548/EEC and 1999/45/EC, are revoked by Regulation 36 of the Biocidal Products and Chemicals (Appointment of Authorities and Enforcement) Regulations 2013, as a result of this legislation.
This comes into effect on 31 May and 1 June 2015.
Well, yes, say the German authorities. They believe that consumer protection can be strengthened by applying the same rules on imported products containing substances of very high concern (SVHCs) as those produced and placed on the market within the EU.
Such changes would present a significant challenge to the European Chemicals Agency (ECHA) in terms of the legal situation, and to produce appropriate regulation, but would allow for a levelling of the playing field, and removing unfair advantages to importers who can get away with not fully complying with REACH.
Such a move would require more testing for SVHCs in articles, to check that labelling claims are correct, and this would obviously require enforcement laboratories to have a suite of validated, accredited measurement methods available for the range of SVHCs which could be encountered.
Filed under: chemicals, ECHA, REACH/CLP | Tags: chemicals, CLP; REACH; Chemicals; ECHA, REACH, Safety Data Sheets
The European Chemicals Agency, ECHA, has issued revised guidance for downstream users under the REACH Regulation. The revision to the guidance document regarding the concentrations of substance posing human health or environmental hazards, substances that are persistent, bioaccumulative and toxic or very persistent and very bioaccumulative, and substances of very high concern (SVHCs) included in the Candidate List for authorisation.
The new guidance states clearly the concentrations of these substances in mixtures formulated by downstream users (DUs) above which Safety Data Sheets (SDSs) are mandatory, so that the relevant information can be properly communicated along the supply chain.
This may lead, in some cases, to the need for analysis of mixtures to be carried out in order to fully understand the concentrations of any hazardous substances present in the mixture. Such analyses must be accurate at the limits specified, and should therefore be carried out by accredited laboratories using validates test methods.