REACH Regulation
Control Techniques Dynamics REACH position statement
In accordance with the requirements of European Regulation
1907/2006 Control Techniques Dynamics have been actively seeking
assurances from our supply chain to ensure continued supply.
Under the regulations which came into force June 1st 2007 there
has been a requirement for chemicals produced and imported into the
European Community in a volume of > 1 tonne per annum to be
registered , evaluated and authorised for use.
The first stage of the approval process for chemicals was for
them to be registered with the newly formed European Chemical
Agency (ECHA)
The regulation defines responsibility for the registration of
chemicals to be by the producer or importer and goes on to use
three pieces of terminology to further clarify these being:-
Substances, Preparations and Articles:
Substances are the chemicals elements in their
natural state
Preparations are a mixture of 2 or more
substances
Articles are finished items produced as part of a
process, which can contain substances and or preparations.
Under the regulation Control Techniques Dynamics is defined as a
producer of Articles and as such we have no responsibility under
the directive to register. We do have however responsibility to
ensure that we notify our suppliers that we use certain Substances
& Preparations within our articles and also to inform our
customers if any of our articles contain substances of very high
concern.
Control Techniques Dynamics have declared that no substances are
released from our articles under normal operating conditions.
Pre registration was allowed up to 31st December 2008, after
this date any chemicals not registered will need to go through the
full approval process.
The ECHA will next determine the evaluation period for each of
the anticipated “30,000” chemicals believed to be in use across the
EU.
The evaluation period will vary depending on the current risk
rating of the chemical. Those known to be substances of highest
risk will carry the shortest evaluation period up to 2018 for the
least risk substances.
The ECHA will publish on their web site (www.echa.europa.eu) a full list of
substances and their evaluation period.
http://apps.echa.europa.eu/preregistered/pre-registered-sub.aspx
The next stage of the evaluation process is to identify
preparations and articles which may contain
Substances of Very
High Concern (SVHC). These are
substances which have been proven or are believed to be
Carcinogenic, Mutagenic and Toxic.
Again the ECHA have published a list of these on their
website.
http://www.echa.europa.eu/chem_data/candidate_list_en.asp
Under article 17 of the regulation Control Techniques Dynamics
have a responsibility to inform our customers that articles
supplied contain SVHC’s.
This will be done after evaluation of our articles with the
assistance of our supply chain. Assurances are being sought from
the entire supply chain about the status of each and every
substance or preparation procured.
This is a momentous task added by identifying those that carry
the greatest risk of containing SVHC’s and so we ask for your
patience whilst we carry out this work.
Control Techniques Dynamics fully support the aims of the
regulation and will keep customers informed of progress and of
course notify them immediately should SVHC’s be identified in the
articles supplied to them.
Ian Hunt
Quality Manager
30th April 2009
To download a PDF copy of the Control Techniques Dynamics REACH
position statement click here