Introduction to REACH and Impact on Metallurgical Consumables for Iron and Steel Foundries

Posted in Industry News on 1st September 2011 |

What is REACH?

REACH stands for the Registration, Evaluation, Authorisation and Restriction of Chemical substances and is a European Community Regulation for the safe use of chemicals. The law (EC 1907/2006) came into force on 1 June 2007 and will have a major impact on the production, import, distribution and costs of supplying materials including metals.

What are the aims of Reach?

REACH aims to protect humans and the environment from the harmful and toxic effect of chemicals.

How will REACH affect the cast metals industry?

A few years ago many of us in the cast metals industry were told there was no need to worry about REACH as it was aimed at the chemical industry.

Excuse the pun, but to understand the reach of this legislation, it is important to understand the meaning of the word ‘chemical'. What REACH covers is ‘chemical substances', defined as any material with constant chemical composition and uniform characteristics that cannot be changed without breaking chemical bonds.

Therefore, the reality is that all metals are classified as chemical substances under REACH, including vital metallurgical consumables like pig iron, silicon carbide, ferro silicon, magnesium ferro silicon, ferro chrome, ferro phosphorous and ferro manganese. This is a major change from pre REACH when all non hazardous classified metal materials supplied to the iron, steel and aluminium Industry were virtually free of any regulation.

Under REACH, it is a legal requirement for any EU producer or importer of metallurgical consumables to register each chemical substance with the European Chemicals Agency. End users in foundries also have a responsibility to ensure they are sourcing materials that have been correctly registered.

What chemical substances does REACH cover?

Approximately 143,000 chemical substances were pre-registered by the 1st December 2008 deadline.

Polymers, part of the plastics related group chemicals are exempt. However, more controversially, REACH does not apply to chemicals used in manufactured products imported into the EU.

Who is responsible for REACH?

The European Commission is responsible for legislation and enforcement, but manufacturers and importers will work closely with the European Chemicals Agency (ECHA) in Helsinki to implement REACH.

How much does REACH cost and who pays?

The registration cost is levied on every chemical substance a Company produces or imports as follows: -

1 to 10 tonnes = € 1600
10 to 100 tonnes = € 3400
100 to 1000 tonnes = € 11,500
1000 tonnes plus = € 31,000

With 143,000 substances and all producers and importers having to register for every chemical substance it's easy to see that REACH places a huge cost on European industry, with estimates varying between € 2.8 and € 8.6 billion Euros over 11 years.

Discounts are dependent on company size as follows: -

Large = 0%
Medium = 30%
Small = 60%
Micro = 90%

On top of registration there are also substantial costs of administration, consultants, testing etc. which are difficult to quantify at this stage.

How will REACH work?

The REACH Process is staggered over many years and can be broken down into 5 main stages: -

Pre-registration and registration of substances by all EU manufacturers and importers.
Group collaboration of manufacturers and importers through SIEFs.
Extensive testing of chemical substances.
Sharing of data.
Identification of risks, improved control measures and use of substitutes or banning of the most dangerous chemicals where possible.

Pre-registration / registration

Each material produced or imported by each producer or importer must have been pre-registered or registered with the ECHA by set deadlines.

1st June 2007 - REACH law came into force.
30th November 2008 - Pre-registration of all substances.
1st December 2010 - Registration of all substances manufactured or imported in quantities over 1000 tonne per year.
1st June 2013 - Registration of all substances manufactured or imported in quantities between 100 and 1000 tonnes per year.
1st June 2018 - Registration of all substances manufactured or imported in quantities under 100 tonnes per year.

Group collaboration through SIEFs

The ECHA will coordinate testing of substances through Substance Information Exchange Forums (SIEFs). These will be formed by groups of manufacturers and importers of the same substance. The theory is that the costs and information are shared by the SIEF and animal testing is reduced.

How this information and cost is shared will be the responsibility of the SIEF, but quite how so many different companies will agree on this matter is not yet clear. Also, for companies outside of the SIEF it is unclear how a fair price will be determined for them to access the data.

Testing

The ECHA and the SIEFs will coordinate extensive testing of each chemical substance, and priority will be given to those suspected of being high risk.

There has been a lot of controversy on the emotional issue of animal testing with chemicals. In November 2005, Guenter Verheugen, the Vice-President of the European Commission, estimated that 3.9 million animals could be used for testing. The Commission has proposed to reduce this figure by 70%, through measures such as better coordination of tests by the SIEFs. MEPs have called for alternative methods of testing to be considered, but it is still not clear how this will be achieved.

In 2009 Thomas Hartung, the former head of the European Centre for the Validation of Alternative Methods (ECVAM) and Constanza Rovida estimated that 54 million animals would be used for REACH at a cost of € 9.5 billion. ECHA questioned the methods used stating that it was 6 times their estimate.

Sharing of data

The ECHA will formulate publically available databases for access by customers and consumer groups.

Identification of risks, improved control measures and use of substitutes or banning

Following testing results, the ECHA will focus on high-risk chemical substances which have serious and irreversible effects under the following categories: -

CMRs - Cause cancer, mutation or reproductive system problem.
PBTs - Break down slowly, accumulate in the body and toxic.
vPvBs - Same as above but take a very long tom to break down.

The European Commission can either ban the use of a chemical in certain products, or ban it completely. Polymers would no longer be exempt if a viable way for testing was developed.

Arguments for and against REACH

For: -

Long term improvements in human health and environment.
An increase in understanding of the properties of chemicals substances.
Encourage E.U. industry to be world leaders in use of new alternative chemical substances.

Against: -

High costs of registration and compliance are an extra burden for hard pressed European industry, especially for small and medium sized companies.
Overly bureaucratic system, involving a huge number of businesses and individuals rather than a corporation tax funded, totally independent and centrally managed system of testing and sharing data.
Potential job losses from international companies moving production to high growth countries with cheaper costs and less regulation.
Suffering of animals from a massive programme of animal testing.
An international framework for the control of use of chemical substances would be a better solution.

Asmet's view on REACH

Clearly REACH's main goals of better health and environment is in all our interests. However, in a globalised industrial world we would like to see the ECHA work with international bodies for a more unified international agreement and framework for the use and restriction of chemical substances. For example, other institutions and standards like the International Material Data System (IMDS) and Global Automotive Declarable Substance List (GADSL) have their own regulations. In the 21st century, do we really need every industry, government and trading bloc with its own separate standard?

European industry is understandably concerned about bureaucracy, red tape and rising costs which could lead to significant job losses if businesses move away from Europe. If manufacturers outside of Europe can continue to use banned or non-registered chemicals in their goods for export to the EU, who is really benefitting?

The EU's chemical industry is a major employer and world leader which employs nearly 2 million people and produces one third of the world's chemicals. Millions of others work in industries such as the cast metals industry which are big users of chemical substances included under REACH, and the costs of compliance will inevitably be passed on to end users. It is absolutely vital that European producers, importers and end users are not left at a competitive disadvantage to the rest of the world.

Asmet Policy - How is Asmet complying with REACH?

Working together with our specialist REACH Consultants, Asmet will ensure that all materials supplied to our customers throughout Europe from our hubs in the UK, Belgium, Germany and Spain are fully compliant with REACH regulations.

For more information, please contact Robert Parker

What do you think about REACH?

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External Links: -

European Commission

European Chemicals Agency

IMDS

GADSL

Tags: Environmental, European Commission, European Union, Health and Safety, REACH