IP REACH: Issue 6
25th July 2015
Re: REACH Compliance
Indestructible Paint, as a supplier of coatings, recognises the role that we have under REACH as a downstream chemical user. We recognise that the REACH regulation places a heavy burden of communication within the supply chain and poses a potential threat to any business operating within the European Union.
We are working with our supply chain and using the data available from ECHA to ensure that we are compliant with the REACH legislation and to avoid any loss of supply continuity.
Indestructible Paint is working to maintain the supply of our coating range with minimal disruption to our customer base. If the supply of one or more of our products is threatened for any reason, all affected customers will be notified immediately. Indestructible Paint is aware that we have coating end users who do not purchase directly from our UK facility. We therefore do not have a full listing of coating end users who will require notification of SVHC or product supply changes. Please contact your Account Co-Ordinator or our Sales Department if you feel there is a communication gap between your organisation and Indestructible Paint.
The REACH/EU requirement to authorise the use Hexavalent Chrome compounds will be the first instance of Chemical restriction that affects Indestructible Paint products. Indestructible Paint is an actor in both the CTAC and CCST Authorisation consortia that are submitting dossiers seeking the continued use of Hexalavent Chrome compounds.
Indestructible Paint is actively developing alternative coating technologies in order to combat current or predicted threats from chemical SVHC classification. Details for these projects are available for discussion via your Account Co-Ordinator or our Sales Department.
In reponse to our obligations under the regulation and enquiries from our customers, Indestructible Paint can confirm the following:
1. 2018 Registration Deadline
Indestructible Paint recognises that the 2018 chemical registration deadline is a potential threat to our business continuity.
Indestructible Paint is not intending to delete any products/product ranges due to the 2018 registration deadline. We have a close liasion with our Raw Material supplier and we are working closely with our supply chain to ensure that there is no immediate threat to any of our coatings.
At Indestructible Paint we identified that we use in the region of 500+ individual raw materials. Our Raw Materials inventory includes 1000+ individual chemical components. Within our capabilities we are monitoring the data issued by ECHA and the UK HSE to ensure that the chemicals we identified within our product range meet the required registration deadlines.
2. SVHC Notification
Indestructible Paint uses chemicals which are on the Candidate List of Substances of Very High Concern (SVHC) for authorisation. These include:
Chromium Trioxide; CAS Number 1333-82-0 / EC Number 215-607-8 which is used in product codes: DOW 19; IP1041; IP9183-R1; IP9184-GREEN; IP9184-KHAKI-R1; IP9356; IP9442; IP9444 and PL177
Strontium Chromate; CAS Number 7789-06-2 / EC Number 232-142-6 which willaffect the following products: IP9064-6362; IP9064-9226; IP9253-R2; IP9310
Pentazinc Chromate Octahydroxide; CAS Number 49663-84-5 / EC NUmber 256-481-0 which is used in product codes: 700-155-003; IP9064-4853; LAS-4853; IP9165-R1; IP8015; 588-0060-3; 40021
n-Methyl-2-Pyrrolidone; CAS Number 872-50-4 is listed on SVHC candidate list. The future of this solvent is currently under review.
Indestructible Paint Ltd is active in two Consortia, seeking authorisation fo rthe future use of Chromium Compounds after their sunset dates. The Consortium for Chromium Trioxide is C.T.A.C (Chromium Trioxide Authorisation Consortium) and C.C.S.T (Chrome Consortium for Surface Treatments) covers other Indestructible relevant chromium compounds.
Indestructible Paint is aware that proposals are in place to add further chemicals to the SVHC list as the REACH process matures. We will continuously update our communication as and when additional chemicals are proposed as an SVHC substance. Additionally, where a product contains a SVHC this is notified on the Certificate of Conformity, Delivery, Technical Data Sheet and SDS Documents.
If any user of Indestructible Paint coatings is concerned with the implications of the revisions to the SVHC list, please send an email to our Sales Department or your Account Co-Ordinator specifying the Indestructible Paint code for the coating in question. Compliance with REACH is an integral part of our business at Indestructible Paint. We will work closely with our customers to ensure a sustained supply of products and to develop the future generation of coating solutions.
Details of the current SVHC list can be found at: http://echa.europa.eu/chem_data/authorisation_process/candidate_list_table_en.asp