REACH for You as a User

REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) is a European Union regulation that addresses the handling of chemicals within the EU and replaces the previously applicable chemical regulations of the individual member states. Its aim is to replace substances which are particularly harmful to the environment or to health with less dangerous substances. The supervisory authority is the European Chemicals Agency (ECHA) based in Helsinki. REACH is introduced in three phases, of which the first two have already been completed. As of 1 June 2018, the third phase will also be: by then, all substances that are produced or imported into the EU in quantities of between one and 100 tonnes must have been reported to the ECHA. Therefore, phase 3 mainly concerns small and medium-sized companies.
 
There is an exception to the rule. ECHA treats analytical activities like scientific research and development. Chemicals used for scientific purposes do not need approval as long as they are used in quantities of less than one tonne per year and in compliance with the usual laboratory guidelines. Chemicals which are used for analytical activities are therefore also need no approval. The ECHA hat published questions and answers for the special arrangements under paragraphs 585 and 1030 on its website.
 

REACH and downstream users

The company Bernd Kraft is presently not subject to registration and is thus considered a downstream user. We buy around 1,500 substances from which we produce our solutions and standards. Hundreds of the substances we purchase have already been registered. However, our customers need not fear any relevant repercussions, because we ensure REACH conformity of all standards and solutions.

Tips & Tricks

The following information as well as the flow chart explain what to do and how to proceed.
 
 
 
 

Safety Data Sheet Issues

 

1. Check which type of safety data sheet (SDS) you have received

  • If you have received a substance-related SDS, check whether your use for the substance is covered in section 1 of the SDS and make sure you comply with the basic occupational health and safety provisions.
  • If you have received an (extended) SDS that contains exposure scenarios, you must check whether these cover your use conditions.
 

2. Does the extended SDS cover your use conditions?

  • Define your own use conditions with the Use Descriptor System (UDS). This is provided by the European Chemicals Agency (ECHA) as a guide. It takes numerous usage processes and sectors into account, is very flexible and allows more than a million combinations of usage.
  • It is based on five separate categories. Each category has predefined descriptors which, when combined, provide a brief description of the use.
  • When defining the use conditions, the aggregate state and concentration of the substance, the frequency and duration of use, the risk management measures and the operating conditions must be taken into account.
  • For your convenience and for better harmonization, we have synchronized our findings within the industry. The resulting sector-specific, harmonized usage overview, along with nutshell descriptions indicating which laboratory activities can be related to which use descriptions, are available on request - contact us by This email address is being protected from spambots. You need JavaScript enabled to view it..
  • Compare your own use conditions with those covered by the extended SDS.
 

3. What to do if the extended SDS does not cover your use conditions

According to REACH articles 37 and 39, you have a 12-month period, starting when you receive a registration number in your supplier's SDS, to cover your use. You have four options:
 
Option 1:
Check whether you can adapt your use conditions so that they are covered by the extended SDS you have received. Changing from an open to a closed application, improving your ventilation system or reducing the exposure time are possibly examples.
Option 2:
Communicate the missing use conditions via your supplier to the registrant and ask the registrant for exposure scenarios which cover your use conditions.
Option 3:
Report your use conditions to the ECHA and carry out your own chemical safety assessment. If you are using the substance in a quantity of more than one tonne (metric ton) per year, you must notify the ECHA within six months that you are conducting a chemical safety assessment yourself. If you use less than a tonne per year, you must only report your continued use to the ECHA. In this case, a chemical safety assessment is not necessary.
Option 4:
Switch to a supplier who can ensure your uses and cover your use conditions.
 

4. Further use of the new SDS information in your facility

Keep in mind that the new, additional information contained in the safety data sheets (including exposure scenarios) that have been sent to you should be integrated into documents such as hazard assessments, hazardous substance registers, operating instructions for dealing with hazardous substances and explosion protection documents. In addition, do not ignore the ramifications for other legal areas, such as the Hazardous Incident Ordinance or the regulations on the storage of hazardous substances.
 
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