The REACH Conundrum

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TaimoorZ
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Re: The R.E.A.C.H. conundrum, the problem
TaimoorZ   1/31/2012 2:05:16 AM
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Seems like REACH operates in a highly decentralized setup. How difficult is it to manage collaborations amongst the different members? In other words, are companies able to share their findings (with regards to new chemical uses, risks associated etc) across the board with other members easily?

Douglas Alexander
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Re: The R.E.A.C.H. conundrum, the problem
Douglas Alexander   1/30/2012 9:45:10 PM
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Taimoorz, The following excerpt is from the ECHA page: Understanding REACH.

REACH is a regulation of the European Union, adopted to improve the protection of human health and the environment from the risks that can be posed by chemicals, while enhancing the competitiveness of the EU chemicals industry. It also promotes alternative methods for the hazard assessment of substances in order to reduce the number of tests on animals.

In principle, REACH applies to all chemical substances; not only those used in industrial processes but also in our day-to-day lives, for example in cleaning products, paints as well as in articles such as clothes, furniture and electrical appliances. Therefore, the regulation has an impact on most companies across the EU.

REACH places the burden of proof on companies. To comply with the regulation, companies must identify and manage the risks linked to the substances they manufacture and market in the EU. They have to demonstrate to ECHA how the substance can be safely used, and they must communicate the risk management measures to the users.

If the risks cannot be managed, authorities can restrict the use of substances in different ways. In the long run, the most hazardous substances should be substituted with less dangerous ones.

REACH stands for Registration, Evaluation, Authorisation and Restriction of Chemicals. It entered into force on 1 June 2007.

 

TaimoorZ
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Re: The R.E.A.C.H. conundrum, the problem
TaimoorZ   1/28/2012 7:31:49 PM
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I may be putting up a very naive question here, but I'm still not sure on what exactly is the primary reason why the Eurpean community is starting REACH program? And essentially, how will it impact companies?

Brian75137
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Douglas's response to Bolaji's question
Brian75137   1/28/2012 1:30:37 AM
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Douglas:

I'm glad to see someone who calls a spade a spade.  With the multitude of governmental agencies which are still proliferating, there's no wonder that there is so much confusion and lack of coherent progress on things like REACH.  It goes to show that we need to cut the size of government and consolidate this type of function.  The same holds true for the vast number of people who are progressing without centrallized direction on the subject of counterfeit parts.  I don't mean that the government should necessarily be the only ones to do it, the private sector has, traditionally, shown that they can do a superb job at something like managing problems like this and usually better and at a lower cost. These problems - REACH and counterfeit parts have been known for a long time and it is only now that it has come to the forefront in the US.  Kudos to you, Douglas, for calling it as you see it without mincing words to be "politically correct:.

Douglas Alexander
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Re: The R.E.A.C.H. conundrum, the problem
Douglas Alexander   1/27/2012 10:55:12 PM
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Bolaji,

That's a big question in a small sentence. If you are referring to the ban on DEHP for infant to early childhood year's products in 2009 by the US subsequent to EU's ban in 1999, we would have to look at what was grabbing the spotlight of politicians and/or legislators in the Unitied States for that 10 year period. So begins the war on terror. 9-11 2001 captivated our nation's hearts, minds, and its resources so thoroughly that priority number one was to respond and adjust to a new, unsafe America and allies around the world. Not much gourmet cooking going on when the kitchen is burning. As late as 2009 we're still up to our eyeballs with terrorist concerns. October 2009 was the 30 thousand troop surge into Afghanistan.

Also, if you look at the European Chemical Agency, (ECHA) and its sweeping authority and comprehensive mandate over all EU participants, they began their assault on hazardous chemical management with a unified front. The United States of America is by no means the United States of the Environment. We have about 14 different government agencies looking at the environment with different interest, time tables, and priorities. The White House has overall policy and agency coordination, but let's look at the departments that needed coordination. The Office of Management and Budget, Money-money-money. The Department of Justice is juggling Environmental litigation. The Department of the Interior is watching overproperty, energy and mineral rights. And, the department of defense, being just a little bit distracted with the war on terror is managing their own pollution control from defense facilities. The Department of State over international environment and the Department of Labor is busy with occupational health concerns. The Council of Environmental Quality also has agency coordination responsibilities along with environmental impact studies and statements. I hear someone asking about the Environmental Protection Agency, (EPA). This agency mainly is concerned with water and air pollution, solid waste, Radiation, Pesticides, Noise, and Toxic substances. and not a very effective agency to my mind because they run headlong into the other agencies juristictions. Quickly for the 10 year era for all legislation: No Air. No Water. No Land. No Endangered Species. No Hazardous Waste. Nada. Zilch, The Big Goose Egg. Nuttin Honey. However, to be perfectly fair, in 2002, we did pass into law the "Small Business Liability Relief and Brownfields Revitalization Act". Congress provides funds to clean up hazardous sites. I don't want this to turn into a rant, but my feeling is apart from the multiudinous agencies with environmental responsibilities, we did have Iraq and Afghanistan eclipsing all else. I promise I will never respond like this again.

Bolaji Ojo
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Re: The R.E.A.C.H. conundrum, the problem
Bolaji Ojo   1/27/2012 8:32:51 PM
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Douglas, Why did it take the US so long to catch up with Europe?

Douglas Alexander
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Re: The REACH conundrum
Douglas Alexander   1/27/2012 3:50:15 PM
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William,

Yes, the plastics in connector housings are a problem after they go back into the landfills etc. Since there is no covalent bonding during the plasticizing process, they do break down back into the nasty stuff fairly quickly. That being said, I think of examples like Kemet with their snap-in, mechanical, and motor start tantalum, electrolytic,paper, and film capacitors that only just cleaned up in December 2011. I still do not suggest that anyone inhales a connector housing with DEHP ;-)

William K.
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The REACH conundrum
William K.   1/27/2012 2:52:50 PM
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My experience with the pthalate family has been with circuit board connectors, where dialyl Pthalate material was very dimensionally stable and electrically neutral. In that application it would be relatively harmless, since circuit card rack assemblies are not something that infants ever contact, and most people never even see. Once again, the danger comes with irresponsible use of something that is fine in other applications. Gasoline is another good example. It is a very effective engine fuel, fairly safe if not mishandled, but using it as a cleaning agent is both toxic and hazardous. But it will clean cloths fairly well, but it is intensely unsafe to use for clothes cleaning purposes.

Douglas Alexander
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Re: The R.E.A.C.H. conundrum, the problem
Douglas Alexander   1/26/2012 10:43:38 PM
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William,

You are one funny guy. You had me in stitches. A little cynicism goes a long way. Did you get a chance to read page 2 witch covers Phthalates, (DEHP)? That is nasty stuff and when they looked at the metabolite volumes in urine from people with major health problems, they found two to three times the amount than the average healthy person. But, the kicker is that the EU knew it was harmful and banned it in 1999 before REACH, but the US kept crankin' out and importing the DEHP in products for infants until 2009. Thanks for the great humor...I know you also mean it.

William K.
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Production Synthesizer
The R.E.A.C.H. conundrum, the problem
William K.   1/26/2012 9:24:19 PM
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Part of the concept of the REACH program is commendable, and yes, it is about a hundred years too late. While it is certainly true that some substances are bad to have around, there are a lot more of them that are able to be problems, but when used responsibly they do not cause any problems. Fried Chicken is one example: As a steadt diet it can be quite unhealthy, but as a once in a while treat it would be fine for most folks. MY point being that in all probability the final rules will treat the fried chicken the same as arsenic tetraflouride, which would be quite toxic if it existed. 

What will undoubtedly happen is that the policy will be that if a lot of something is bad, than any small amount is unacceptable, That mentality has already appeared in other legislation and it is certainly appealing to those who make their decisions based on emotions. 

I am certain that the nagative aspects will be almost enough to cause a re evaluation of the entire concept. But the result will be more similar to "blowing the lid off of Pandora's Box."

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