EPI Health and Safety

REACH

The REACH regulations were adopted in December 2006. REACH stands for “Registration, Evaluation, Authorisation (and restriction) of CHemicals”. This is a complex piece of legislation that will affect manufacturers and importers of chemicals, preparations (such as adhesives, paints, etc.) and “articles”, which include all types of electrical components, sub-assemblies and equipment. There are no exemptions for such as transport, aerospace, etc.

These regulations have been adopted because of the many thousands of high volume chemicals used in the European Union. Today there is no risk data available on 21% of them; inadequate data on 65% and only 3% are fully tested. This means that it is almost impossible to choose a “safe” substance due to a lack of data. REACH aims to ensure that all substances are fully tested.

As most of our customers are aware, the EU has passed a very important and complicated piece of legislation (REACH) that will have wide ranging impacts for many years ahead. REACH will require the registration, evaluation and authorisation of chemicals manufactured and imported into the European Union. We are reviewing this legislation and are preparing for such registrations as are required.

The majority of EPI Service Limited’s products are classed as Articles and as such fall inside the scope of REACH. We will be working in cooperation with our suppliers to ensure that these raw materials are themselves registered. The REACH legislation will have a significant impact on all manufacturers, importers and downstream users in the EU, which will demand close collaboration across all supply chains.

We are committed to meeting all our legal obligations under REACH, but given the complexity and timings required for registrations the downstream impact of this legislation is still being evaluated. At present, there are no plans to withdraw any EPI Service Limited product because of registration issues and we have not been informed by our suppliers of any raw material withdrawals. If the situation changes with any of our suppliers or our own manufactured products, then we will communicate with those customers potentially affected at the earliest possible moment.

EPI Service Limited is now a registered under REACH with ReachReady and this gives as the legal advice we need to comply with this legislation.

We are breaking our compliance of REACH into 2 phases: The main emphasis for EPI is on the most dangerous substances and on those used in the manufacturing processes of our products and of those products we import. To that end phase 1 will concentrate on SVHC’s used in our products. This will be completed by the end of Jan 2009. Phase 2 will start in Apr 2009 and will concentrate the other chemicals that may be used within the manufacturing process. This will be the largest amount of data collection for us and it is aimed for full completion by the end of 2009 financial year.

Should you have any questions regarding this please do not hesitate to contact our H&S department.

RoHS Vs REACH

The basis for RoHS and REACH substance restrictions are quite different. RoHS restrictions are based on hazards - if a substance is hazardous and there are alternatives, then it could be banned. REACH restrictions are introduced only if a risk to human health or the environment can be proven, it cannot be controlled and substitutes exist.

RoHS restrictions can be imposed without a full assessment of the impact of the possible alternatives. It is enough to show that there is a potential risk without evidence of an actual risk. For example, lead is banned by RoHS but there is no evidence that its presence in electronics has or is harming human health or the environment. Also, the possible substitutes had not been identified when this restriction was imposed in 2002 and although less hazardous substitute solder alloys have since been found; their impact was not known until some years after the RoHS lead ban.

The impact of lead solder substitutes is now known because the US EPA carried out a life cycle assessment which shows that neither lead solders nor lead-free solders are clear "winners" overall as they each have different impacts.

REACH restrictions are based on lengthy risk assessments that consider research into the impact of the substance in its entire life cycle and also the possible alternatives. This also considers the control measures used by industry to minimise risk and social and economic issues. REACH restrictions are likely to be application specific where a risk is identified although total bans are also possible.

The other main difference is that RoHS bans substances present in electrical equipment that is within the scope of this directive. REACH affects all chemicals including those used to make the equipment (alloys, solvents, paints, etc.) and chemicals present in finished products of all types. There are very few exclusions and exemptions.

For advice and or quote please do not hesitate to contact us