REACH A Jotun Perspective
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1 REACH A Jotun Perspective
2 Aims of this presentation To identify key stages of what needs to be done to achieve compliance with REACH (Registration, Evaluation, Authorisation of Chemicals) Regulations To formulate an action plan with time scales and responsibilities To periodically review and take corrective actions where the plan is not on target
3 What are the key stages?/ 1 Look at all the raw materials and intermediate products (preparations/ substances) that go into current products gather information on quantities, suppliers, hazardous properties Look at raw materials with higher hazards and tonnage that are critical to key finished products Ascertain geographical sources of these key raw materials (EU or non EU) Establish a dialogue with these suppliers with a view to ensuring that they will Pre-register and follow through the materials we are interested in especially the smaller local companies Contact key customers and let them know that Jotun would be taking all necessary steps to ensure continued supply
4 What are the key stages?/ 2 Work closely with trade associations (British Coatings Federation at UK level and CEPE at European level) to develop a common industry strategy Carry out a screening process to highlight all products/ raw materials that will need further work on exposure scenarios & chemical safety reports based on their classification Allocate roles and responsibilities for the product stewardship SDS, labelling, Chemical safety assessments & chemical safety reports, documentation
5 Action Plan/ 1 Corporate Product Safety Group (PSG) to identity all raw materials and finished products that would come within the scope of REACH by late 2007 & pre-register relevant chemicals with European Chemicals Bureau (or ensure that suppliers have done so) Local REACH Coordinators in the EU to supply details of any noncorporate substances to the PSG by late PSG to identify substances not likely to be presented for Authorisation by Suppliers, review the implications on Jotun finished products and advice relevant manufacturing sites of potential loss of key raw materials & suggest alternatives mid 2008
6 Action Plan/ 2 PSG to allocate responsibility to teams for identifying customer uses & exposure scenarios based on hazard characteristics mid This will be based on dialogue between customers and Jotun. Key substances supplied from outside EU will be a priority target to get them pre-registered and ensure that the suppliers are in the process of getting Authorisation responsibility PSG team.
7 Review and corrective actions REACH responsible person from PSG (Product Safety Group) and EU based local REACH Co-ordinators will meet quarterly to check on progress against this Action Plan and take corrective actions where required to ensure full compliance with REACH This is indeed a resource and knowledge intensive exercise and Senior Mangers of individual companies are well advised to prepare for compliance NOW! [If they haven t started yet!] Finally Jotun sees REACH not as a threat but as an opportunity to ensure better living and working environment for all Those who work with a positive attitude will reap rewards of a stronger financial status and public acceptance.
8 Resources available to UK Companies/ 1 Support is available from various sources such as: HSE helpdesk: ECB: Trade associations such as CIA (no, not the Criminal Investigation Agency) ( British Coatings Federation
9 Resources/ 2 Chemical Hazards Communication Society Private Consultants plenty on the Internet University of Hull has a post graduate Course on REACH
10 Progress Update as on 22 February 2008/ 1 We have used a lot of resources to prepare for contacting our suppliers regarding pre-registration. To make good lists of the suppliers of each raw material and their contact details have showed to be difficult, as the data are not present in one system. Project Responsible 1 & 2 have made lists based on the information in Info System for Sandefjord, on lists from you, and on input from Powder Coatings.
11 Progress Update / 2 We have looked for good systems for the communication in the supply chain. This has been challenging. We have tested REACHway in 3 months, but did not find it user-friendly enough and have left this system. In these days Info System (the SDS supplier) is introducing a new module that will be used in the communication. Letters are already sent to all Powder suppliers, and the letters to the paint suppliers will be sent out next week. AMN is responsible for the communication regarding preregistration.
12 Progress Update/ 3 The goal is to have an overview by the 1st of October, to decide the pre-registration we have to carry out ourselves. The work in the exposure scenarios group are about to start and resources have been dedicated to this work. This group will start to group products, and develop/collect information regarding uses, risk management measure and exposure data for the uses. This will be entered in the new SDS - REACH module. The goal is to send this out to the suppliers in the early autumn.
13 Progress Update/ 4 We have finished the check of CMR, PBT and vpvb substances and have ended up with only a few. Letters to the suppliers of these are being created now, and we will ask whether we have the right information, and how they will handle the situation. R&D is informed of the raw materials that are covered in this group, and it is decided to stop to use most of these raw materials inside EU.
14 Progress Update/ 5 We have regularly meetings in the steering committee, and are now discussing with Info System how this system can be developed to meet our REACH demands. I have also sent some questions to ECHA based on input from various persons in Jotun. I am participating in the CEPE-REACH groups to keep updated and contribute to the branch work on REACH. So far little is done by CEPE to prepare for REACH. I am also following the development of the RIP documents, which seems to be a never-ending story.
15 Progress Update/ 6 This was a very quick overview! I hope gives you some of the input you wanted. If you have more detailed questions, please ask me!
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