Feature article: PIM International, Vol.1 No. 3 September 2007, pages 43-51, 4449 words

Author: Peter Brewin, Consultant, UK

Former Technical Director, European Powder Metallurgy Association, UK

Introduction

In this specially commissioned review for Powder Injection Moulding International, Peter Brewin, former Technical Director of the European Powder Metallurgy Association (EPMA) reports on REACH, a new European Union law affecting European manufacturers and importers of chemical substances. REACH came into force on 1st June 2007 and includes metals, alloys and other raw materials. The new law therefore affects the whole PIM industry.

he REACH Regulation [1] completed the legislative process in Brussels in December 2006 and entered into force ('EIF') in all EU member states on 1st June 2007. The immediate effect is to place a large bureaucratic burden on manufacturers and importers ('M/I') of chemical substances based in Europe in assembling the registration dossiers which are at the heart of the regulation. Irrespective of whether a chemical substance has proved a problem in the past, these dossiers must demonstrate that its intrinsic hazards have been quantified, and measures proposed to control risks of human and environmental exposure appropriate to each identified use, right down the supply chain, including disposal.

Different deadlines are set depending on tonnage; the registration dossier for most bulk chemicals will have to be completed by December 2010. After the different deadlines it will be illegal for unregistered suppliers to place chemical substances on the market. (This will have important implications for company purchasing policies). Additionally users of chemical substances share legal responsibilities for correct risk management under the duty of care provisions of the Regulation.

A key element of REACH is the legislative treatment of chemicals known to be highly dangerous. In its full effect REACH is intended to eliminate these from Europe. In the interim, continued use of these will be subject to an authorisation process to minimise risks to humans or the environment. Chemicals which are proven or suspect human carcinogens are liable to authorisation.

Although simple in concept, the application of REACH to producers and importers of metals and chemicals is highly complex, involving as it does the formation of registration consortia, and close cooperation through the entire supply chain. Most EU member state governments have set up REACH helpdesks (see e.g. [2]). Several substance-based or European-wide trade associations are offering assistance to their members (see e.g. [3,4]). To minimise duplication and share costs M/I are likely to want to cooperate with M/I of the same chemicals, and are advised to start by contacting the relevant trade association for that chemical substance....

Further sections of this article include:

- WHAT IS REACH?
- REACH: Main aspects
Registration timescales
Authorisation ('adequate control and eventual replacement')
Importers
REACH implementation projects ('RIP’s')
The GHS
- Powder specific issues
Inhalation hazards
Environmental hazards
The assessment of alloys
- REACH and PIM
- Health aspects
Particulates
Binders
- Registration
Parts producers
Powder makers
Feedstock producers
- Authorisation
Powder makers
Feedstock producers
- Authorisation

Figures and Tables:

Fig. 1 Main REACH definitions

Fig. 2 Timescales for Registration Entry into Force ('EIF' = 1 June 2007)

Fig. 3 Exposure Routes for hazards to human health and the environment

Fig. 4 Particle size and respiration [8]