The ECHA (European Chemical Association) regulation known as REACH is designed to prohibit the presence of chemicals known to harm human health and the environment in products manufactured in or imported into the EU.
These banned chemicals are known as substances of very high concern (SVHC), and as a manufacturer your goal is to eliminate them from your products and your supply chains. It’s also possible to get temporary authorization from ECHA to have an SVHC in your product provided you can prove there are no viable alternatives and that any health/environmental risks are adequately controlled.
If your business needs to comply with REACH, eliminating SVHCs is vital. For the typical EH&S manager, this means identifying where these banned chemicals are in your existing chemical inventory and finding reasonable alternatives.
However, it’s not enough to simply remove SVHC from your current materials: because the candidate list of SVHCs is always growing, a good EH&S manager will take a proactive approach and prevent banned substances and potentially-banned substances from entering their facility.
A Systems Approach to Chemical Vetting
This is proactive chemical management: using ban lists and your own corporate sustainability goals as filtering tools for selecting vendors and for accepting chemical products from your suppliers.
Of course, proactive chemical management for REACH could potentially take a great deal of time if you aren’t putting a good system in place to support it. As with most EH&S tasks, doing it by hand is possible, but generally ineffective. It’s better to implement a system that follows this basic 4-step process:
- Digitize and standardize incoming chemical records from suppliers (make sure all data follows the same template and the same logic).
- Create and maintain a list of banned substances and substances you voluntarily avoid.
- Compare the ban list with any incoming chemical records – flag those with matching CAS numbers and/or chemical names.
- Prevent the import of chemical records and products that have been flagged until an EH&S specialist or chemical inventory manager approves/vetoes.
A proactive system that does, at a minimum, the four above steps is a strong proactive step to ensure nothing you purchase inadvertently compromises your REACH efforts – an unexpected change from a vendor won’t catch you off guard.
Keep in mind that a system like the one described above will need regular maintenance and upkeep: since the candidate list for SVHCs is continuously getting updated, your ban lists will also need to be updated. If you build a system yourself, be sure to schedule time once a month to review the ECHA lists and update your own ban list. It’s also possible to find a system (including the one designed by ERA) that includes regulatory monitoring done for you, so you never have to worry that your ban list is out of date.
Authorizing Chemicals through ECHA
There is a process for getting chemicals that you cannot outright ban authorized for use in any product you plan on exporting to the EU.
It’s worth noting that getting a product authorized for use in your supply chain is a temporary solution with a lengthy procedure – it’s a far better solution to find a reasonable alternative substance if you can.
ECHA outlines an application procedure you can follow. You can view the complete process online here, but we’ll outline the basics here:
- Find out whether you are affected by authorization. Find out if the material is on the list of materials that can be authorized and if there are any relevant exceptions.
- Communicate with your supply chain and develop a strategy for authorization. This is a process that affects your whole supply chain and will require research about the processes of your suppliers.
- Start to gather information and prepare your reports. Identify where SVHC are used in your facility and your supply chain.
- Notify ECHA and get your pre-request information session to learn exactly what you’ll need.
*Note: ECHA requires notification at least 8 months prior to you submitting your application.
- Finalize your application.
- Submit your application to ECHA.
- Follow along with and contribute to the stages of public commentary and debate. Within the next 10 months the ECHA Risk Assessment Committee and Socio-Economic Analysis Committee may ask you to provide further information or justification.
- Comply with whatever conditions ECHA determines after the decision-making process.
As seen above, getting a chemical authorized takes months to years of research, applications, and management. A good chemical inventory system and some sort of supply chain management can make the process easier (particularly steps 2, 3, and 5).
Becoming Proactive Instead of Reactive
REACH compliance will never be simple, but it can be a much more streamlined process by implementing systems to switch you from reactive to proactive.
- Get proactive about banning or flagging SVHC before they get brought into your facility through digital standards and automation.
- Streamline authorization by centralizing all chemical inventory data and supplier data, making it easier to compile applications and find the information you’ll need.
- If complying REACH is becoming a burden or you’re worried about its impact on your profits, the most effective solution is to implement a system that handles the complex chemical comparisons and presents all the information you need up front.
November 18, 2015