As a specialist customer rubber compounder, Clwyd Compounders Ltd has operated a policy of reducing the amount of hazardous substances used in rubber formulations for many years. The arrival of REACH has great potential to simplify this process, by collecting a large amount of materials knowledge and expertise, and standardising the language used to describe it. The major problem is the sheer size and scope of REACH; this is an ambitious and extensive piece of legislation, with an implementation plan extending over many years. It can initially appear very daunting, particularly to Small and Medium Sized Enterprises (SMEs), whose business planning timeframes tend to be very much shorter than the 10 years envisaged by REACH. Effective implementation requires a general understanding of the big picture, followed by a rapid narrowing of focus to concentrate on the major issues which will be important to the individual business over the next 2-3 years. From the viewpoint of a "formulator", the paper discusses: o The main processes of REACH, and how new classification, packaging and labelling (CLP) legislation will link with these 1. The implementation experience to date 2. Ongoing implementation issues:- 1. The importance of taking a pro-active approach to the identification of hazardous substances, with examples of current priorities. 2. The implications of CLP legislation. 3. Case Study: the replacement of phthalates in rubber compounds.
展开▼