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REACH Regulations Affecting the Plating Industry

August 10, 2010

As the Works Chemist of a small electroplating firm based in Kent, UK I have been asked by my Director to determine the extent of our obligations under the REACH regulations. As a company we buy in a number of chemicals that are currently listed as (Substance of Very High Concern) SVHC or are being proposed as SVHC. In recent times we have received documents from our suppliers informing us that the products we use contain an SVHC in a concentration at or above 0.1%.

We were recently asked by one of our customers whether the electroplating service we offer will at some stage require REACH authorisation as the plated components will naturally contain trace amounts of SVHC.

My current interpretation of regulations suggests that we are unaffected. As a supplier of Articles only, as defined by EU Reach Regulation and estimated usage of any one substance per Article produced would not equal a ton of the substance/year per article. In addition the proportion of SVHC (e.g Chromium VI) present in a passivate layer per article is not greater than 0.1% by weight.

Please could you advise me as to the nature of our REACH obligation.

Lewis Mortimer
Plating shop works chemist - Ashford, Kent, United Kingdom
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First of two simultaneous responses -- August 10, 2010

Lewis-
Here in the US, the National Metal Finishing Resource Center (NMFRC) had compiled some guidance documents for REACH. They are primarily aimed at assisting US metal finishers who export plated products to Europe, but there is some useful stuff for you there as well. Here is the link...
http://www.nmfrc.org/compliance/reach.cfm

Jon Barrows, MSF, EHSSC
Springfield, Missouri



Second of two simultaneous responses -- August 11, 2010

Lewis,

REACh has become the bane of our lives anywhere we use chemicals. Sometimes it is unclear what is required of us.

So, first of all I would recommend you check out the ECHA website, this has a massive amount of information and a lot of guidance notes. The guidance notes do take some wading through but if you are going to be the company REACh point of contact it will be worth it.

Secondly check out the UK HSE website. They have several good leaflets on your REACh obligations as well as links to the ECHA and other useful resources.

The declaration of SVHCs over 0.1% in articles is covered by two Articles of REACh.

Article 7 requires the declaration to the ECHA of any SVHC present in articles intended for release to the environment where that substance is present in articles at greater than 1 tonne/annum in importation or manufacture.

Article 33 requires that you tell your customers, within 45 days of request and free of charge whether there is any SVHC at greater than 0.1%, regardless of the amount of the substance that is used in manufacture or by importation per annum.

I would strongly recommend that you check out the ECHA and HSE websites before you go back to your boss and tell him what he needs to do.

Brian Terry
aerospace - Yeovil, Somerset, United Kingdom


August 13, 2010

In UK the Institute of Metal Finishing (IMF) regularly updates members on REACH as it applies to this industry.

There is a link from this website or go directly to

http://www.uk-finishing.org.uk/index.htm

and follow the link to REACH.

Look out for Southern Branch seminars on the subject and get the opportunity to discuss the problems with others in the same boat. See you there.

Geoff Smith

Geoff Smith
Hampshire, England

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