A provocative title which the Swiss Federal Office of Public Health (OFSP) hopes, in its flyer on REACH, to attract the attention of all industrial companies to this EU Directive which appears to be about to impose severe constraints. So what is it all about?
Reach – so what is really behind it?
The website of the Swiss Federal Office of Public Health, OFSP, provides this answer: ‘REACH is the abbreviation for Registration, Evaluation, Authorization of Chemicals and also includes the restrictions applicable to these substances. This is the new EU Directive which aims to make the manufacture and use of chemical substances more safe within the EU.’
Reach entered into force on 1 June 2007 and relates to chemical products for which pre-registration by 1 December 2008 is mandatory at the European Agency for Chemical Products (ECHA), based in Helsinki. This mandatory requirement applied to known substances which were manufactured or imported in quantities greater than or equal to one ton per annum by the manufacturer or by the importer. Registration of new substances started on the 1st of June at the same agency.
Who is affected?
The ‘REACH’ Directive affects companies based in the EU which are required to request pre-registration of new products, or the registration of existing products in question. Swiss companies are affected if they export their chemicals – i.e. the products manufactured by themselves – to a country of the European Union.
Does this affect machining companies?
A bar-turner product (for instance) – depending on the description of that company’s activity – involves workpieces machined from (for the most part) metallic materials. To do this, bar-turners necessarily use products such as cutting oils or cooling fluids, and all these products can be viewed as chemical substances. After the machining operation, as a general rule, the workpieces are washed before being supplied to a customer. In such cases, the bar turner does not supply any product of a chemical nature, and is therefore not affected by REACH. In cases where the bar-turner is going to be machining synthetic materials, he is well advised to first contact the supplier of this material to ask whether a conformity declaration can be provided and, if not, can then press for one.
If a bar-turner then gets involved in assembling several components on behalf of a customer in the EU, or for a customer who will be exporting to the EU, that bar-turner may find himself affected by this Directive. This depends on the lubricant content, and the content of other chemical products in this sub-assembly. Depending on the case involved, it may be necessary to follow the same procedure as the machine manufacturers.
What about machine-tools?
The manufacturers of machine-tools are subject to the same Directive as any other producer. The decisive point is to know if a material or a product used in a machine – for example oils or greases – is affected by REACH and if the quantity exported in this case exceeds the official annual limit of one ton. To recapitulate: it does not matter if a product is exported directly or via an intermediary. The manufacturer involved must, if certification is not already provided by his supplier, must take steps to obtain written confirmation that the product (oils, greases) has been registered with the appropriate authority in Helsinki.
Doubt is permissible
This is relatively complex subject matter, something which even the specialists dealing with this subject are willing to admit. Doubt is therefore allowed. To learn more, the interested party can consult the OFSP website, or one of the other websites listed later in this article. Moreover, all manufacturers of related substances involved directly or less directly have been looking at this issue for some time and are now in a position to provide fairly accurate information on this question.
For example, the lubricant manufacturer Blaser SA is providing a specific e-mail address ([email protected]) where questions can be tabled on this subject. Motorex is another company willing to provide information through the following e-mail address: ‘[email protected]’.
Internet websites to consult:
http://www.bag.admin.ch/themen/chemikalien/00531/02835/index.html?lang=fr (In French and German)
… and there are plenty of other websites out there.
E-mail address of Blaser SA : [email protected]
E-mail address of Motorex SA : [email protected]
Thank to Robert Meier, freelance specialist journalist, Rupperswil for this point on REACH.
I don’t think this will directly affect machining companies, but what about the products they use? Will we see a reduction of the chemicals on the market? Does it mean that machining or cleaning will become more difficult due to reach compliants chemicals?
In case of doubts, don’t hesitate to contact lubricant companies (as mentionned here above) or also cleaning companies like www.amsonic.com