CoRAP Hits The Floor

REACH regulation's CoRAP evaluation process of chemicals has begun; CoRAP substances are on the floor and open to discussion.

REACH CoRAP The first Community rolling action plan (CoRAP) contains 90 substances that the Member States will evaluate under the substance evaluation process of the REACH Regulation. These substances are evaluated in 2012, 2013 and 2014. Online there is a list of CoRAP substances included in the CoRAP -- to be evaluated by the European Member States in the next three years. For each substance in the list, there is a designated Member State, the year of evaluation and a short description of the initial concern.

Following the established risk-based criteria, ECHA and the Member States identify a number of substances that could be included in the CoRAP. (Member States will express interest in evaluating a certain substance, from that ECHA can create draft CoRAP, which will include the substance names and the tentative assessment years.)

The final, meaningful CoRAP is adopted after consultation among the Member States and the opinion of ECHA's Member State Committee. From the publication of the draft CoRAP, substances may be added or removed before ECHA adopts the final CoRAP. The final CoRAP indicates the initial concerns over the substances and designates the Member States that will carry out the evaluation.

ECHA will adopt the first CoRAP in 2012 (that's now) with a first update scheduled for 2013. ECHA will submit draft annual updates to the CoRAP to the Member States by 28 February each year (that's last Tuesday).

CoRAP uses Member States will evaluate certain substances to clarify whether their use poses a risk to human health or the environment. Under this process it is possible to request further information from the registrants of the substance to verify the suspected concern, if necessary. The evaluation may conclude that the risks are sufficiently under control with the measures already in place or it may lead to the proposal of EU-wide risk management measures.

The management of chemical risks requires commitment from both industry and the authorities. The substances for evaluation under CoRAP are selected on the basis of scientific, risk-based criteria.

ECHA Proposes 13 New Candidate SVHCs

The European Chemicals Agency has announced that a 45-day consultation period began yesterday, February 28, for selection of the next set of 13 new candidate substances of very high concern (SVHCs).

(See current list of 73 SVHCs here).

The list of substances is within the press release, along with a general indication of where they believe the substances are used. Also, the proposal is accessible online.

If you are managing REACH issues for an electronics company or your products incorporate electronics, note that one of the substances, "Diboron trioxide" (also known simply as "boron oxide"), is widely used in surface-mount resistors and capacitors. It is classified as toxic for reproduction category 1B (per the CLP regulation, (EC) No 1272/2008).

The next step, after the 45-day period is over, is for ECHA and the member states to review the comments and decide on the final list of candidate SVHCs. When that is announced they will immediately be reportable under article 33 of REACH. Expect that to happen in the June/July timeframe.

See:

ECHA press release

DCA Associates (REACH consultants, US west coast)

www.Actio.net (REACH software, US east coast)

ECHA Launches C&L Inventory of Chemicals

ECHA launched (today, February 15, 2012) the Classification and Labeling Inventory of chemicals on the EU market. You can view the ECHA press release, or go straight to key inventory reference links:

• Public C&L Inventory: http://echa.europa.eu/information-on-chemicals/cl-inventory
• C&L Inventory Q&A: http://echa.europa.eu/support/faqs/q-a-on-the-public-cl-inventory
• C&L Inventory Factsheet: http://echa.europa.eu/documents/10162/17242/factsheet_public_classification_labeling_en.pdf

Webinar February 16th: Supplier Data and Compliance

This looks like a good webinar for REACH data gathering -- upstream and downstream. This is a paid webinar on Thursday February 16th at 1PM Eastern.

Cost: $99
Host: NAEM, the U.S. based National Association for Environmental Management

Experts from 3E Co. and Actio Corp. will show how EHS and sustainability managers can effectively create a cohesive, efficient and effective Compliance program resulting in a consistent source of supplier compliance data shared across the enterprise. Automating the process of supplier data management will be emphasized, along with best practices that apply to any such program.

Attendees will take away insights that include:

• How leading-edge companies gather supplier data for REACH, RoHS, WEEE and TSCA compliance
• Proven management systems that reduce regulatory and product stewardship risks throughout the supply chain
• How to create quality programs that allow your company to connect automatically and meaningfully to suppliers, not just today but continuously over time
• Techniques for using technology to streamline supplier relationships and compliance processes, saving time, money and headaches
• How your company can collaborate with suppliers to support the needs and goals of both parties
• Five best practices you may not have thought of

Source: NAEM web site via LinkedIn: Environmental, Health & Safety Compliance Network (you have to be signed into LinkedIn for that link to work, fyi)

Of the WWS category: Webinars Worth Sharing.

ECHA Study: New CLP Pictograms Unfathomable to Public

Most readers will know that the European Chemicals Agency (ECHA) submitted a key report to the European Commission on January 20th, 2012. The report analyses efforts thus far to communicate hazards to the public via labeling and packaging.

The report can be distilled to one simple finding: The general public has no idea what the new CLP label pictograms mean.

Apparently two separate surveys found that the public doesn't understand the pictograms on the new CLP labels one iota. So here's a quiz. How many of these pictograms do *you* quickly grasp from these warning images?

Danger:
rolling pin

Alert:
Native American

ceremonial wheel


Heads up:
Prime-time TV police drama
marketing swag

Answers to pictogram quiz
There aren't many calls for humor in our line of work, so this was fun. Here are the real answers:

1. Rolling pin = gas under pressure (!)
2. Native American ceremonial wheel = oxodizing substance or mixture (!)
   
3. Police marketing swag = health hazard (well, ok, that one seems reasonable after the first two)
   

Thus...
Industry should be encouraged, says the report, to bring product appearance and packaging more in line with the hazard information on labels, making use of behavioral drivers to amplify the label's message -- thereby promoting the associated safety behavior in consumers. Basically, industry is encouraged to keep explaining the labels.

Changes to the CLP labels themselves are not recommended. Authorities believe it's more beneficial to allow the public to get used to the new system – now in use globally – steadily improving the public's overall understanding of the hazards posed by chemicals and encouraging a safer use of household chemicals in particular.

According to Article 34 of the CLP Regulation, the European Commission will follow up by submitting a related report to the European Parliament and the European Council in order to, if justified, present a legislative proposal to amend the Regulation.

More information

Report Title: Communication on the safe use of chemicals Report. Subtitle: Study on the Communication of Information to the General Public.

Study on Communication on the safe use of chemicals to the General Public, submitted to the European Commission on 20 January 2012:
http://echa.europa.eu/documents/10162/17203/clp_study_en.pdf

Risk Communication Network (RCN):
http://echa.europa.eu/en/web/guest/about-us/partners-and-networks/risk-communication-network

Article 34 of the CLP Regulation:
http://echa.europa.eu/web/guest/regulations/clp/legislation

CLP Deadlines & Fees:
http://www.environmentalleader.com/2010/12/30/europes-clp-regulation-overview-deadlines-and-fees/

13 New SVHCs Slated for Authorisation List (Ban)

The European Chemicals Agency (ECHA) is on the move -- and has named/proposed 13 new substances for the Authorisation List. This means ECHA recommends that 13 Substances of Very High Concern (SVHCs) should not be used without authorisation from now on. These substances are all classified because of their carcinogenic, mutagenic or toxic to reproduction (or a combination thereof) properties. They are used in applications where there is potential for worker exposure.

The 13 chemicals in question are listed below, or you can view them on the ECHA web site: ECHA's 13 new chemicals.

From its list of candidate substances, ECHA says it prioritized the 13 substances in spring this year based on:

1. their hazard properties
2. the volumes used
3. the likelihood of exposure to humans

The Agency says it took comments into account from the public consultation period (between mid June and mid September). An overview of the authorisation process under REACH: http://echa.europa.eu/web/guest/addressing-chemicals-of-concern/authorisation

This is the third time that the Agency recommends substances for authorisation (the first was in June 2009 and the second in December 2010). More on 3rd recommendation: http://echa.europa.eu/web/guest/addressing-chemicals-of-concern/authorisation/recommendation-for-inclusion-in-the-authorisation-list/previous-recommendations/3rd-recommendation

ECHA also says it considered the opinion of the Member State Committee, whose majority supported ECHA's conclusion that all thirteen SVHCs should be included in Annex XIV. More on Member State Committee's opinion: http://echa.europa.eu/documents/10162/17087/opinion_draft_recommendation_annex_xiv_third_en.pdf [PDF]

The 13 substances are:
The thirteen substances and their main uses within the scope of authorisation are:

1. Trichloroethylene (carcinogen). A substance mainly used in surface cleaning, in textile scouring, in adhesives and as a heat transfer fluid.
2. Chromium trioxide (carcinogen, mutagen). A substance mainly used for metal finishing and as a catalyst.
3. Acids generated from chromium trioxide and their oligomers (group containing: chromic acid, dichromic acid, oligomers of chromic acid and dichromic acid) (carcinogen). A substance that could be used to replace chromium trioxide in many of its uses.
4. Sodium dichromate (carcinogen, mutagen, toxic for reproduction). A substance mainly used in metal surface treatment.
5. Potassium dichromate (carcinogen, mutagen, toxic for reproduction). A substance mainly used in metal surface treatment and as a processing aid.
6. Ammonium dichromate (carcinogen, mutagen, toxic for reproduction). A substance with currently no uses in the scope of authorisation. It could however be used to replace other chromium(VI) substances.
7. Potassium chromate (carcinogen, mutagen). A substance mainly used in metal surface treatment.
8. Sodium chromate (carcinogen, mutagen, toxic for reproduction). A substance mainly used in metal surface treatment.
9. Cobalt(II) sulphate (carcinogen, toxic for reproduction). A substance mainly used in surface treatment processes and as a water treatment chemical, oxygen scavenger and corrosion inhibitor.
10. Cobalt dichloride (carcinogen, toxic for reproduction). A substance mainly used in surface treatment processes and as a water treatment chemical, oxygen scavenger and corrosion inhibitor.
11. Cobalt(II) dinitrate (carcinogen, toxic for reproduction). A substance mainly used in surface treatment processes and as a water treatment chemical, oxygen scavenger and corrosion inhibitor.
12. Cobalt(II) carbonate (carcinogen, toxic for reproduction). A substance mainly used in fertilisers and in surface treatment processes.
13. Cobalt(II) diacetate (carcinogen, toxic for reproduction). A substance mainly used as a catalyst and in surface treatment processes.

REACH Regulation Threshold Amounts

Overview / background to understanding threshold amounts For chemicals on the REACH regulation Candidate List, and there are currently 73 SVHCs listed, there are restrictions in terms of what quantity of that chemical you can use in your products and under what conditions these restrictions apply. A large part of the restriction is in terms of threshold amounts. These may not be exceeded under the law of REACH.

REACH thresholds: 0.1% For clarification, there are 4 main areas where the REACH threshold amount applies. The most important one for most businesses is the first. If any SVHC on the candidate list is present in an article with a concentration above 0.1% (w/w) and the total amount of the SVHC exceeds 1 tonne per annum, per producer or importer, you need to act. Just contact ECHA right away and ask what to do. If you do not want to draw attention on the matter just yet, contact a 3rd-party private chemical data supplier. Here is a list of 3rd-party tools for REACH (etc) compliance, prepared and published by a green chemistry association out of U. Mass. Lowell: GC3 Retailer Portal.

Notification requirement: You must submit notification to ECHA if any SVHC on the candidate list present in an article has a concentration above 0.1% (w/w) and the total amount of the SVHC exceeds 1 tonne per annum, per producer or importer. The SVHC candidate list is updated from time to time, with the most recent update in December of 2011.

Communication requirement: If any SVHC on candidate list is present in your product with a concentration above 0.1% (w/w), you are obliged to inform the recipients of the article along the supply chain about the chemical name(s) and how the article can be safely used. REACH further requires this information be made available within 45 days upon consumer request.

Restriction requirements: Article suppliers not only need to comply with the requirements of that SVHC, they also need to comply with the requirements of REACH Restriction. For example, AZO dyes and nickel release are on REACH restricted substances list (XVII of REACH).

Authorization requirements: Priority SVHCs on the candidate list will be included in the Annex XIV of REACH (the "Authorization List"). Those SVHCs will not be allowed to be used, placed on the market or imported into the EU after a date to be set -- unless the company is granted an authorization.

This post would like to send a shout out to the Textile and Leather Chemical Regulation & Testing Service who have put together a nice page on REACH and their information organization was helpful in creating this post.