The REACH (Registration, Evaluation, Authorisation and restriction of Chemicals) Directive has been in force since June 2007. This legislation affects all members of the SEA who use chemicals during their surface engineering processes. Amongst the many aims of the REACH Directive was to provide a high level of protection to human health and the environment from chemicals.
The Directive applies to chemicals which are manufactured or imported into the EU as a substance on its own, in a mixture of substances, or produced during surface finishing processes, in quantities of one tonne or more per year.
As from 1st December 2008, these chemicals have to be registered with the European Chemical Agency. Your supplier will be able to let you know if the chemicals they are supplying you with have been registered already or will need to be registered by yourselves.
HSE guidance advises companies to compile an inventory of every chemical used during your processes, such as any chemicals coming into or leaving the business and what feedstocks, intermediates and products are used or created. By keeping records of every substance used and the amount for each application, you will be able to determine the tonnage used per year and whether you will be required to register them.
Companies working in the surface engineering sector will have to comply with REACH for the following applications:
· Chemicals such as trichloroethylene used for surface cleaning prior to plating or anodising
· Chemicals used in the electrolyte solution during the surface coating process
· Any chemical by-product produced during the surface coating procedure
Heavily restricted hazardous substances
Certain hazardous substances, identified as substances of very high concern (SVHC), have a restricted use and can only be used under authorisation. The use of hexavalent chromium falls under this restriction due to its toxicity and for being a known human carcinogen, as well as the use of cadmium for plating owing to the environmental toxicity of the metal.
Companies involved in developing new processes and coatings must consider letting their chemical supplier know what the substances are being used for, as this use may not be within the remit of their existing registration.
For further guidance on the REACH Directive and how it affects your applications and processes contact firstname.lastname@example.org. You can also find information on the HSE website at http://www.hse.gov.uk/reach/index.htm