Author Archives: Kal

About Kal

Kal Kawar, CIH, PE, has a bachelor's in chemical engineering and a master's in industrial hygiene. His professional experience includes serving as staff industrial hygienist for IBM's New York semiconductor manufacturing facility, and as industrial hygienist for IBM’s US headquarters. Now executive vice president of Actio, Kal taps more than 20 years' worth of chemical engineering, industrial hygiene, and environmental engineering experience. His far-reaching expertise with global regulatory challenges created by EPA, TSCA, REACH, RoHS, WEEE – and hundreds of others – aid in developing Actio software solutions for MSDS management, raw material disclosure compliance, and product stewardship in a supply chain.

ACC-tung Baby: New Tool For TSCA

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Pressure to modernize TSCA is mounting from all sides, and the American Chemistry Council (ACC) is offering a tool that agencies can use to do something about it.  The ACC is proposing a chemical prioritization system that it believes could be used by the Environmental Protection Agency (EPA) to determine which chemicals warrant additional review and assessment.

Achtung means “Pay attention” in German, and the world is indeed paying attention to TSCA reform.

ACC President and CEO Cal Dooley said as part of the new tool’s announcement, “As outlined in ACC’s principles for modernizing the Toxic Substances Control Act (TSCA), establishing a clear and scientifically-sound prioritization process is key to creating a world-class chemical management system.”

The 35-year-old TSCA law does not dictate a process to utilize the information currently available to prioritize chemicals for review.  ACC’s approach offers one way to evaluate chemicals against transparent, consistent and scientific criteria that take into account both hazard and exposure. In this system, chemicals are given a score based on certain criteria and then ranked based on both:

  1. scores, and
  2. the agency’s best professional scientific judgment

Those rankings would then be used to determine which chemicals should be referred to EPA’s Office of Chemical Safety & Pollution Prevention for further assessment.

Conflict of interest? The obvious problem with ACC contributing a chemical prioritization tool to EPA lies in seemingly inevitable conflicts of interest where an industry-backed association has a stake in evaluating its own products (in this case chemicals) for the marketplace.

ACC says its prioritization tool is not intended to produce conclusions about which chemicals necessarily present a risk to human health or environment. The tool is, apparently, just a gift, simple as that.

EPA’s stakeholder meeting on prioritization. On Sept. 7, before the announcement, representatives from ACC met with officials at EPA to discuss the tool in conjunction with the agency’s stakeholder dialogue on prioritization.

[EPA is opening an online discussion forum for comment from hrough Sept. 14 to get input on the prioritization factors and data sources the Agency plans to use to identify priority chemicals for review and possible risk management action under TSCA.  Participate here.]

“We are glad that EPA has recognized the urgent need to prioritize chemicals for review,” said Dooley. “ACC welcomes the opportunity to participate in [this] dialogue and hopes EPA will utilize our concepts to develop a consistent and transparent prioritization process.”

For more and for reference, see: www.americanchemistry.com/Policy/Chemical-Safety/Chemical-Safety-Regulations

 

15 Bad Intentions Under REACH

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Three new restriction proposals for NPs and NPEs have been announced under REACH.  Specifically, the three are:

  1. 4-nonylphenol, branched
  2. nonylphenol
  3. nonylphenol ethoxylates

NPs and NPEs are grouped under alkyl phenols and their ethoxylates.  Sweden has proposed intentions to restrict the three substances.

Notification of intention: September 2, 2011
Expected date of submission: August 3, 2012

Currently, most substances under intention for restriction are mercury compounds and phthalates.  To view or download the list of 12 substances with intention for restriction under REACH see below or download REACH’s12 intentions.

The Swedish Chemicals Agency understands that the proposed restriction is a new restriction, not an amendment of an existing one.  (The amendment of an existing restriction requires first a decision according to REACH article 69(5) to amend the restriction and then a decision according to the normal procedure amending the restriction.)

Justification for the three new proposed market restrictions for 4-nonylphenol, branched and nonylphenol and nonylphenol ethoxylates is reportedly based on Sweden’s understanding that:

  1. NP (e.g., nonylphenol) and NPEs (e.g., nonylphenol ethoxylates) have been found in environmental samples taken from freshwater, saltwater, groundwater, sediment, soil and aquatic biota
  2. NP has also been detected in human breast milk, blood, and urine and is associated with reproductive and developmental effects in rodents
  3. NP is persistent in the aquatic environment, moderately bioaccumulative, and extremely toxic to aquatic organisms
  4. NP has also been shown to exhibit estrogenic properties in vitro and in vivo assays. NP’s main use is in the manufacture of NPEs
  5. NPEs are nonionic surfactants that have been used in a wide variety of industrial applications and consumer products. They can be found in textile (including leather) articles
  6. NPEs, though less toxic and persistent than NP, are also highly toxic to aquatic organisms, and, in the environment, degrade into NP
  7. Levels of NP in waters above the environmental quality standards in the Water Framework Directive (WFD) is found in several waters despite the strict restriction on the use of Nonylphenol (NP) and Nonylphenoletoxilates (NPEO) under the limitations directive 76/769/EEC (now in Reach Annex XVII, entry 46) having been in force since January 2005
  8. NP and NPEO in textiles have been identified as a significant source of NP in the environment

Based on these data, the Swedish Chemicals Agency is investigating the possibility to propose a restriction on the placing of the market of textile and leather articles containing NP or NPEO.

REACH Gets A 5-Year Review

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It’s been five years since REACH* was adopted. Now, five years later, the European Commission (EC) is preparing to review the legislation.

The review is expected to be significant but not overwhelming. The EC-led review will be based on “lessons learned” from the implementation of REACH, focusing on the costs and administrative burden and other “impacts on innovation.”REACH regulation The review will include:

    1. Test method costs and spends: an audit of the amount and distribution of funding made available by the EC for the development and evaluation of alternative test methods.
    2. REACH scope: whether to amend REACH scope to avoid overlaps with other EU legislation.
    3. ECHA: a review of the European Chemicals Agency (ECHA).
    4. Lower tonnage substances: a review of registration requirements for lower tonnage substances.

‘So, how’s my driving?’ Originally, REACH sought to test, analyze, categorize and track ~100,000 chemical substances. But since 2006, only a small number of chemicals have actually been reviewed, starting with a list of 47 Substances of Very High Concern (click here for full SVHC list), which are suspected of causing cancer or disturbing the human reproductive system.

“But there are a lot more substances out there,” said Jamie Page from the Cancer Prevention and Education Society, as reported by Euractiv.

Page is calling for the screening process to be accelerated. “Obviously, there are a lot of chemicals on the market – people estimate between 80,000 and 100,000 – so it is like a few down, a lot to go.”

ChemSec, an environmental lobby group, has recently accused the EU of delaying action on “endocrine-disrupting” chemicals such as phthalates, calling on regulators to speed up work. ChemSec wants 378 substances included in the SVHC list. “There are a lot of controversial products,” Page concurred, citing Bisphenol A, a compound which has recently been banned in plastic baby bottles but which some scientists believe could be harmful in other guises, such as coatings for food cans.

Activist lawyers ClientEarth and chemicals campaigners ChemSec recently said they had sued ECHA for refusing to disclose the names of facilities producing 356 potentially dangerous chemicals. ECHA told Reuters in May it had decided to publish company names ONLY in the case of firms that are suppliers of hazardous substances, but that those entities and stakeholders could request confidentiality.

For producers of nonhazardous chemicals, the disclosure would be voluntary.

Notes: * REACH is the European regulation for the safe use of chemicals. REACH deals with the registration, evaluation, authorization and restriction of chemical substances. Adopted in 2006, it entered into force on June 1, 2007. The European Chemicals Agency (ECHA), based in Helsinki, Finland, acts as overseer of the REACH system.

REACH strives to do two things: 1) catalogue all ~100,000 chemicals in use today, and 2) set restrictions on uses of toxic chemicals.

ECHA guidance: http://guidance.echa.europa.eu/index_en.htm

EPA’s New GHG Reporting Program: e-GGRT

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The US Environmental Protection Agency (EPA) has announced a new tool to allow 28 industrial sectors to submit their 2010 greenhouse gas (GHG) pollution data electronically.

Grabbing ahold of industry’s GHG data is a bit like grabbing a tiger by the tail.

Tiger by the tail. The electronic GHG Reporting Tool is known as e-GGRT for short, a gritty, growly and staccato moniker for a function that is precisely that. Reporting GHG data is a nuts and bolts effort, slightly predatory, that can only be done one data piece by one data piece.

A user can hope for speed and a usable interface, but one thing we’ve noticed in our years of environmental data consolidating — from relatively simple MSDS data fields to more complicated supplier material disclosure data — is that bulk uploads are great but one by one is inevitable. Meaning: data has to be culled. Do it at the start, do it later which is more difficult as time creates data dependencies, but evenutally data must be culled. (This is the type of project companies rightly outsource.)

EPA says that it put the e-GGRT through its paces before making yesterday’s announcement. More than 1,000 stakeholders, including industry associations, states and NGOs tested the electronic GHG Reporting Tool (e-GGRT) — testing for clarity and user-friendliness.   Apparently it passed.

It’s e-GGRRRREAT? The EPA expects to receive 2010 greenhouse gas data from approximately 7,000 large industrial greenhouse gas emitters, including power plants, petroleum refineries and landfills. The agency plans to publish non-confidential greenhouse gas data collected through the tool by the end of 2011.

If you missed the August 1, 2011, deadline, go ahead and register or have your agency register anyway; EPA is likely to be lenient.  They want a queue of data more than they want a queue of wrists to slap.

On August 19 (2011) EPA Head Lisa P. Jackson signed a final action related to certain data elements reported under EPA’s Greenhouse Gas Reporting Program. EPA says it needs to further examine the likely business impact from the disclosure of these data elements before they are reported and potentially subject to public availability. This action defers the deadline for reporting these data elements while EPA addresses issues related to reporting and public availability of these data elements. In fact, EPA is deferring the reporting deadline for some of these inputs until March 31, 2013, and for others until March 31, 2015. This action does not affect the reporting deadline for other data elements under the rule or for suppliers of greenhouse gases.

To compare EPA’s e-GGRT tool with a commercial Greenhouse Gas reporting tool, Google search for emissions regulator tools. Here’s one example of a commercial tool.

On the EPA Confidential Business Information (CBI) page. Also, EPA & Air policy is online.

For $12B, Google Buys Motorola’s Insured Supply Chain

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The Google-Motorola deal announced last week is about hardware manufacturing capability.  In other words, Google just paid $12.5 billion for a gadget supply chain with over 20,000 patents as the cherry on top.

As Chris Nowak put it in a recent article in Environmental Leader about quality management in a modern supply chain, “Today’s business problems include how to compete with a supply chain like Apple’s – a bristling hot pot of electronics suppliers and logistical hubs that delivers a customized, monogrammed electronic gadget in 3 days or a book you order today that’s delivered tomorrow, or the sneakers that you design to wear next week.

“Like it or not,” writes Nowak, “this is today’s competitive field.  All this speed still has to be cost-effective, innovative, compliant and risk-analyzed for whatever market it’s being made in and sold into.  Today’s global supply chain has blink-fast distribution demands.”

It couldn’t be more true.  What Motorola has is a hardware supply chain for gadgets comparable to Apple’s; now Google has one too.  That’s a large chunk of the $12 billion, and that chunk that was worth it.

The environmental compliance piece. What’s notable from our point of view is that Motorola has in recent years made significant efforts in its supply chain environmental compliance.  Their supply chain risk in terms of compliance vulnerabilities is low, low, low.

Motorola has for years been actively collecting supplier chemical information, fortifying compliance efforts with REACH, RoHS and other environmental regulations — imposed by both government and industry alike.

Did Google see that as part of the value?

Did Google acquisition executives see this material disclosure data as significant portfolio gold that may continue to return value?

As regulations tighten worldwide and the pressure mounts to know what’s happening at the chemical level in an electronics (or in any discrete manufacturing) supply chain, Google will know.  Their competitors?  Not so much..

Microsoft, Apple and Oracle have a new and sudden weak spot. While the term material disclosure has more than one meaning, some call it “supply chain insurance.”  Here’s how Motorola — in just a few years — has insured its supply chain.

“We require our suppliers to disclose an extensive list of Motorola Solutions’ banned, controlled and reportable substances as well as request recycled material content for each part supplied to Motorola Solutions,” says the company.  “We do this to fully understand and track the material content of our products, to comply with regulations, prepare for future regulations and control and improve the environmental profile of our products.”

This is not a partial approach.  It’s bold and thorough.

If you think about all the law suits that fire back and forth between the tech giants like Google, Apple, Microsoft and Oracle — the giants without material disclosure insurance seem suddenly keenly vulnerable in the environmental, sourcing, and quality assurance heel.

Motorola’s material disclosure advantage. Motorola Solutions — in its corporate documentation — discusses how its taken a proactive approach and compiled a list of 63 substances (or substance groups) targeted for exclusion, reduction or reporting during the design and manufacture of products. The list is divided into three sections:

  1. Banned substances which are not allowed for use in any Motorola Solutions product at any level
  2. Controlled substances which are limited for use in manufacturing processes or certain product applications (use limitations are typically defined by national or international environmental regulations)
  3. Reportable substances which are are not currently banned or controlled for use, but are likely to be in the future or the company has identified the need to understand their use as part of a environmentally conscious design process and/or for end-of-life management

Motorola has for years now required its suppliers to fully disclose information on the materials composition of parts and components, including information on substances of concern and recycled material content.  The company collects, stores and published information about internal efforts in researching alternative materials and stewardship regarding batteries and other end-of-life concerns.

Regulatory specifics. Motorola has been a leader in recognizing that many countries around the world have implemented regulatory restrictions on hazardous substances.

  1. European Union’s directive on the restriction of hazardous substances (RoHS):  Motorola Solutions complies with the European Union’s directive on the restriction of hazardous substances (RoHS) for electronic products sold in the EU. The company voluntarily extended compliance with the European Union’s restriction of the hazardous substances (RoHS) directive to cover all newly designed professional and public safety two-way radio products as well as mobile and wireless products for the enterprise, regardless of where they are sold worldwide.
  2. China Management Methods:  China’s Management Methods for Controlling Pollution from Electronic Information Products requires manufacturers to report and label usage of the same six hazardous substances listed in the EU RoHS Directive affective as of March 1, 2007. All Motorola, Inc. and Solutions products manufactured after March 1, 2007 and shipped into China comply with the labeling requirements of China Management Methods.  Motorola posts a direct phone line where you can call to get more information.
  3. REACH:  REACH, the European Union substances regulation that entered into the force of law on June 1, 2007, has notable phased deadlines to 2018. The broad regulation requires communication throughout the supply chain, and Motorola Solutions has been “actively sharing information to meet our obligations and help our customers meet theirs.”

The Wily Larry Page. Acquiring Motorola Mobility’s environmental compliance and collection of material disclosure information from suppliers may not be the final straw that flips the other turtles onto their backs.  But it may.  In the meantime, the value of the logistical aspects of Motorola Mobility’s logsitical supply chain is not to be overlooked.

Not everything Larry Page, Inc., also known as Google, has done in 2011 has been amazing, but this deal is a smart, wily, forward-thinking acquisition for a number of reasons — from risk management right down to the chemical level.

EPA Induces ToxCast Labor, Hires 4 Companies

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Interesting news:  The U.S. Environmental Protection Agency’s (EPA) ToxCast chemical screening program has awarded contracts to four United States-based companies to test up to 10,000 chemicals for potential toxicity to people and the environment. ToxCast is designed to determine how chemical exposures affect human health.

The idea behind ToxCast is that it will be able to screen thousands of chemicals in fast, cost-effective tests.  A key goal of the initiative is to reduce EPA’s reliance on slow and expensive animal toxicity tests, enabling the agency to screen chemicals more quickly and “to predict and identify potential risks to Americans.”  Frankly testing mice and bunnies does seem, besides distasteful, a bit archaic.

The companies are:

All four companies will likely hire new employees as a result of these contracts, and it’s good that EPA considered this in the selection.  The companies have offices across the U.S., including smaller markets such as Michigan.  Two of the companies — Vala Sciences and BioReliance — are small businesses.

The four companies will initially screen up to 1,000 chemicals currently in the ToxCast program using innovative technologies such as stem cell toxicity tests. These new technologies can quickly determine the potential for a chemical to cause harm to the human body.  Screening results from the new technologies will be combined with data already being generated by the other 500 rapid chemical tests used by EPA’s ToxCast program.

The chemicals ToxCast is now screening are found in industrial and consumer products, food additives and drugs.

EPA scientific studies using ToxCast have already been published in peer-reviewed science journals, and demonstrate the ability of ToxCast to predict a chemical’s potential to cause several diseases.

For more information on ToxCast database:  http://actor.epa.gov/actor/faces/ToxCastDB/Home.jsp

Image credit: Jack Dykinga – USFWS/public domain

The Notorious B.P.A. – EPA Takes Action

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Bisphenol A (BPA) is currently banned in a checkered way across the United States and across the world. Canada and all the European Union have banned BPA in some uses, and now China and Malaysia have too. So where is the US at a federal level in regards to BPA regulation, you might wonder?

Well, wonder no more. Today the US Environmental Protection Agency (EPA) announced that because BPA has been shown to cause reproductive and developmental effects in animal studies, EPA is requesting public comment on possible toxicity testing and environmental sampling to study BPA’s potential environmental impacts.

BPA lines a can of worms. BPA is a chemical that has, in fact, been shown to mimic estrogen and has been linked to increased risk of cancer, altered brain development, early puberty and other metabolic changes. We’ve avoided discussing it in this blog because – frankly – it’s a can of worms.

You might think we mean the “public perception vs. industry interests” can of worms, but what we really mean is another can: many types of plastics, not just BPA, have tested positively for endocrine manipulation.

Time magazine pointed out a recent study in the journal Environmental Health Perspectives where researchers found that many plastic products leach endocrine-disrupting chemicals — even products labeled “BPA-free.”

In the study, researchers tested 455 common plastic products and found that 70% tested positive for estrogenic activity [EA]. Once those products were subject to real-world conditions—microwaving or dishwashing—the number rose to 95%. The study concluded: Almost all commercially available plastic products we sampled, independent of the type of resin, product, or retail source, leached chemicals having reliably-detectable EA [estrogenic activity], including those advertised as BPA-free. In some cases, BPA-free products released chemicals having more EA [estrogenic activity] than BPA-containing products.

Given that context, it sometimes seems there’s a witch hunt on for BPA. But if BPA is going to serve as a regulatory driver for health issues associated with consuming food stored or served in plastics in so many countries around the world, it’s likely to be at least discussed here in the U.S. too. The comments to EPA will likely be a rousing debate — so keep an eye on the discussions!

EPA, Dell, Sprint and Sony Have New E-Waste Policy

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The US Environmental Protection Agency made a Big Announcement this week in Austin, TX, regarding e-waste and product stewardship — the announcement came as EPA head Lisa Jackson stood beside leaders from Sprint, Dell and Sony.

In Austin, EPA Administrator Jackson signed a voluntary commitment agreement with Dell CEO Michael Dell and Sprint CEO Dan Hesse to promote a US-based electronics recycling market. Sony Electronics Inc. representatives were apparently present and “also committed to improving the safe management of used electronics,” but it wasn’t clear whether they signed anything. But their presence indicates good intentions.

“Americans generate nearly 2.5 million tons of used electronics each year,” said Chris Nowak of Actio Corp., the New England-based company that tracks manufacturing regulations worldwide and bundles these findings into product stewardship compliance software.*

“This is a key commitment made today by Dell, Sony and Sprint,” Nowak said. “Evolving end-of-life policies such as these force designers, quality assurance personnel and manufacturers to think differently about their products and their product quality.”

Michael Dell, chairman and CEO, Dell Inc. said, regarding the stewardship initiative, “Last fiscal year, we diverted more than 150 million pounds of end-of-life electronics globally from landfills, and we are well on our way to meeting our goal of recycling 1 billion pounds by 2014. We encourage everyone in our industry to commit to easier, more responsible recycling as we all work to protect our planet.”

E-waste not, want not. Under the strategy announced today, the US General Services Administration (GSA) says if products do not comply with comprehensive and robust energy efficiency or environmental performance standards, those products will be removed from the information technology purchase contracts used by federal agencies.  GSA also says it will ensure that all electronics used by the Federal government are reused or recycled properly.

Key components of today’s announced strategy include:

  1. using certified recyclers
  2. increasing safe and effective management and handling of used electronics in the US
  3. working with industry in a collaborative manner to achieve that goal.

For more information on the EPA and industry collaboration, click here.

Electronics stew:  wardship and US policy. It’s not the first time we’ve heard rumblings of this sort. Last October, Lisa Jackson visited China — including a site visit to Guiyu, home of perhaps the most famous e-waste dump but certainly not the only one.   And just a few weeks ago a new e-waste bill was proposed by US Representatives Gene Green and Mike Thompson, with a focus on the exports of used electronics. It’s called the Responsible Electronics Recycling Act. It establishes a new category of “restricted electronic waste” — that is — waste that cannot be exported from the US to developing nations.

Exemptions from the bill include:

  1. used equipment can still be exported for reuse as long as it’s been tested and is fully functional
  2. nonhazardous parts or materials are also not restricted
  3. crushed cathode ray tube (CRT) glass cullet that is cleaned and fully prepared as feedstock into CRT glass manufacturing facilities.

WEEE WEEE WEEE. In other responsible product end-of-life news: in February 2011, members of the European Parliament (MEPs) passed new WEEE guidelines for electronic waste.  Key points are as follows:

  1. manufacturers would help pay for goods disposal
  2. EU governments would implement more stringent penalties for breaching, e.g, for falsely identifying shipments as “reusable”
  3. authorities would be able to target all WEEE categories
  4. current ambition levels for collection rates would be maintained
  5. European standards would be set for collection, recycling and treatment for WEEE management.

For full details, see article on the top 5 WEEE bits.

Europe accepts a RoHS. In related RoHS news, the Council of the European Union (“the Council”) officially revised the RoHS directive earlier this summer. In the Big Picture, this critical recast attempts to harmonize the directive across the European Union.

In the smaller picture, RoHS affects hazardous substances in electrical and electronic equipment.  The chemical restrictions will now apply to all electrical and electronic equipment, as well as to cables and spare parts, and to medical devices, medical equipment, control and monitoring equipment – which were previously exempt from RoHS compliance but are not exempt now.

ECHA Updates Criteria for Accredited Stakeholders

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Ever wondered what it takes to become an accredited stakeholder in the eyes of ECHA, the European Chemicals Agency, which is the governing body of REACH regulation?

A stakeholder is defined within ECHA as “an individual, group, institution or government with an interest or concern, either economic, societal, or environmental, in a particular measure, proposal or event.”

ECHA´s Management Board just revised the criteria that defines how stakeholder organizations are granted an accreditation with ECHA.  Here are the five eligibility criteria for so-called Accredited Stakeholders, as amended:

Criteria 1 – Established in and for the EU

An entity seeking status as an accredited stakeholder must be legally established within the EU/EEA and have activities at the EU level.  This means that an eligible organisation has to be legally established in one of the EU Member States, Iceland, Liechtenstein or Norway.  EU level activities are activities targeted at an EU-wide audience, i.e. not limited to the local, national or regional level. To prove it, the place of legal establishment may be evidenced by the founding document or any other suitable document proving that the entity’s seat is located in the EU, Iceland, Liechtenstein or Norway. (Organisations can explain the scope of their activities in the application form.)

Criteria 2 – Legitimate interest

The entitiy must have a “legitimate interest” in the areas of work of ECHA. This means that the organisation applying for accredited stakeholdership represents a sector affected by the EU chemicals legislation (such as the REACH, CLP, Biocides or PIC Regulation) falling within the scope of the tasks of ECHA. An organisation is also considered to have a legitimate interest in the areas of work of ECHA if it represents a sector indirectly affected by the legislation; this can also include non-governmental organisations (NGOs) engaged in issues affected by the mentioned legislation.  Typcially, ECHA’s Accredited Stakeholders are active in industry, human health, animal welfare, environmental protection, scientific research and development, and consumer protection.  Organisations are expected to depict their legitimate interest in the application.

Criteria 3 – Representative

The entity must be “representative” in the field of their competence.  This means the organization must represent the interests of a substantial part of the actors in its field of competence.  ECHA’s Accredited Stakeholders should be representative of actors in their sector or field of competence.  The necessary number of member organisations and their size depends on the structure of the relevant sector.  (Note: the sector need not have a particular size, but must be distinguishable from other sectors with different fields of interest.)  Organisations are expected to set out why they can be considered “representative” in the application form.

Criteria 4 – Non-profit

Entities must be “non-profit” and not exclusively represent individual companies.  A non-profit organisation here means one which is not operating for its own commercial profit or gain but conducts its operations for the benefit of its members or of the general public.
Non-profit status may be evidenced by the founding document or any other suitable document and must be provided during the application process.

Criteria 5 – Register

Organization must be registered in the Register of Interest Representatives maintained by the European Commission. This criterion only applies in cases where the organization wishes to participate as an observer in the Committee and Forum meetings of ECHA. There is no charge to register, it’s necessary for tracking the flow of information.

All organizations are requested to indicate their registration number in the application form.

Note:  all accredited stakeholders who wish to attend ECHA Committee and Forum meetings need to sign up in the Transparency Register, which is operated by the European parliament and the European Commission.

REACH Guidance EZ – Documents For the Rest of Us

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Those interested in REACH regulation should know that the European Chemicals Agency (ECHA) has published a new version of its Guidance in a Nutshell.  Relevant to any company that makes, sells, buys or even thinks about finished goods, it’s called “Guidance in a Nutshell on Requirements for Substances in Articles.”

The updated “Guidance in a Nutshell” is a good document for those of us who are engineers, and who are not lawyers or overly obsessed with the finer points of Policy minutiae. The document addresses in simple terms the primary bullet points of ECHA’s new version of the Guidance on Requirements for Substances in Articles, itself something of a monster (worth wrestling with for some of us, but not all).

The Nutshell document’s aim is to help companies who produce, import or supply articles.  Specifically, it will help them to identify their obligations regarding substances in articles under REACH.  The document briefly explains key bullets such as:

  1. the concept of an article
  2. obligations for registration, notification and communication
  3. possible exemptions from these obligations

Here are the links you need:
Guidance in a Nutshell on Requirements for Substances in Articles:
http://guidance.echa.europa.eu/docs/guidance_document/nutshell_guidance_articles2_en.pdf

Guidance on requirements for substances in articles:
http://guidance.echa.europa.eu/docs/guidance_document/articles_en.htm

General ECHA guidance website:
http://guidance.echa.europa.eu/index_en.htm