Assent Compliance REACH Compliance Webinar

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Assent Compliance hosts regular webinars which cover compliance for REACH, RoHS , CLP and many other environmental regulations. To view the web cast online visit www.assentcompliance.com

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Assent Compliance REACH Compliance Webinar

  1. 1. AS SENTCOM PLIANCEinfo@assentsvhc.com w w w. a s s e n t s v h c . c o m tel: 866.964.6931 REACH – New SVHCS, New AutHoriSAtioNS, NewiNterpretAtioN, New report assent compliance Krystal Noseworthy-BaKer phone: 613.882.1429 krystal.baker@assentcompliance.comcustom solutions for compliance [ reach | rohs | cpsia | rsl | prop65 ]
  2. 2. AS SENTCOM PLIANCE info@assentsvhc.com w w w. a s s e n t s v h c . c o m tel: 866.964.6931 INTROduCTION TO ASSENT COMPLIANCE assent compliance • Consulting • Global Requirements • Compliance Strategies • Regulatory Interpretations and Impacts • IT • Cloud Computing • Application Design • Operations • Program Implementation • Data Management custom solutions for compliancy [ reach | rohs | cpsia | rsl | prop65 ]
  3. 3. AS SENTCOM PLIANCE info@assentsvhc.com w w w. a s s e n t s v h c . c o m tel: 866.964.6931 AgENdA • Headlines • Updates to REACH • Impacts • SVHCs • Additions • Upcoming Additions • Impacts • Authorisations • France’s Article Interpretation • First Report on REACH • Enforcement • Q&A custom solutions for compliancy [ reach | rohs | cpsia | rsl | prop65 ]
  4. 4. AS SENTCOM PLIANCE info@assentsvhc.com w w w. a s s e n t s v h c . c o m tel: 866.964.6931  HEAdLINES reach in the news On Dec 13th, 2006 – REACH was approved Between updates to guidance, industry re- by the European Parliament and hit the news- sponses to REACH, updates to the SVHC wire throughout Europe and North America. Candidate List, and other regulatory devel- opments REACH remains in the news. substances tIon for cHemIcal tImesofmalta.com reacH and tHe electronIcs supply cHaIn:r eacH: a new regula – are you ready? – eetImes – may 2008 doubts remaIn over new reacH- eu cHemIcals law In swItzerland – sw Indu stry could face eu t yle rules – just-food.co IssInf m – oct 2009 o.org s cals l aw acH cHemInews | europerea ctIon to re bc –b tHe fIgHt to Know? substan ces of very HIgH concern ow under reacH and tHe cItIzens’ rIgHt to Kn ober 2010 – european envIronmental board – oct european parlIament approves la w regulatIng cHemIcals – usa today regulatory treatm ent of “artI cles” under reac Icals ul ate toxIc cHem y tImes) dIvergence of Inte H rules to reg rpretatIons betw een ecHa and eu sets tHe frencH comp Ibune (n Ional Herald tr etent autHorIt y – july 2011 rnat – busIness – Inte custom solutions for compliancy [ reach | rohs | cpsia | rsl | prop65 ]
  5. 5. AS SENTCOM PLIANCE info@assentsvhc.com w w w. a s s e n t s v h c . c o m tel: 866.964.6931 reach in the news (cont’d) • China is now spending billions of dollars throughout Europe which will exponentially increase trade between these two countries as well as providing a substantial influx of money not only for the economy in general but for compliance enforcement. This will also serve to increase the impact of REACH as China and Europe will work together for compliance optimization. • Finally, we are seeing GMP laboratories in India being accredited by the Organisation of Economic Cooperation and Development (OECD) in order to reduce the cost of REACH compliance for the chemical industry. Indian chemical exports are expected to double in the next 3 years and REACH will impact most if not all of those exports. custom solutions for compliancy [ reach | rohs | cpsia | rsl | prop65 ]
  6. 6. AS SENTCOM PLIANCE info@assentsvhc.com w w w. a s s e n t s v h c . c o m tel: 866.964.6931 wHAT dOES THIS ALL MEAN? • REACH is going mainstream • The more attention a regulation gets in the media, the more attention your customers give to it » More information requests » Contract changes • Compliance is mandatory to continue business » More declaration requests » Increased standards for declarations custom solutions for compliancy [ reach | rohs | cpsia | rsl | prop65 ]
  7. 7. AS SENTCOM PLIANCE info@assentsvhc.com w w w. a s s e n t s v h c . c o m tel: 866.964.6931 SVHC BASICS svhc basics Article 33 – Source of compliance requirement: Duty to communicate information on substances in articles: 1. Any supplier of an article containing a substance meeting the criteria in Article 57 and identified in accordance with Article 59(1) in a concentration above 0,1 % weight by weight (w/w) shall provide the recipient of the article with sufficient information, available to the sup- plier, to allow safe use of the article including, as a minimum, the name of that substance. 2. On request by a consumer any supplier of an article containing a sub- stance meeting the criteria in Article 57 and identified in accordance with Article 59(1) in a concentration above 0,1 % weight by weight (w/w) shall provide the consumer with sufficient information, available to the supplier, to allow safe use of the article including, as a minimum, the name of that substance. custom solutions for compliancy [ reach | rohs | cpsia | rsl | prop65 ]
  8. 8. AS SENTCOM PLIANCEinfo@assentsvhc.com w w w. a s s e n t s v h c . c o m tel: 866.964.6931The relevant information shall be provided, free of charge, within 45 days of receipt of the request.• What does this mean? • Once a substance has been added to the SVHC List, you must declare its presence to your downstream users if the concentration is above 0.1% of your products weight. • This is to be done upon immediately for professional customers and within 45 days from request for consumers.custom solutions for compliancy [ reach | rohs | cpsia | rsl | prop65 ]
  9. 9. AS SENTCOM PLIANCE info@assentsvhc.com w w w. a s s e n t s v h c . c o m tel: 866.964.6931 SVHCs – CONSTANT uPdATES • Current Candidate List sits at 53 substances • There are currently 20 substances proposed for addition to the Candidate List (proposed Aug 29th, 2011). There are also 8 substances on the Registry of Intentions. • The last update to the Candidate List was June 20th, 2011. • Updates have been happening about twice a year, however this is not a firm requirement, in fact, substances can be added MORE OFTEN. • The head of the ECHA has stated the 136 SVHCs would be listed by the end of 2012 • Current projections state that there should be about 74 substances by the end of 2011 • This leaves 62 substances to be added in 2012 custom solutions for compliancy [ reach | rohs | cpsia | rsl | prop65 ]
  10. 10. AS SENTCOM PLIANCE info@assentsvhc.com w w w. a s s e n t s v h c . c o m tel: 866.964.6931 REACH current svhc candidate list substance uses/materials Anthracene Manufacture of dyes, pyrotechnics Hardener for epoxy resins (possible use in PCBs), hardener in adhesives, intermediate in the manufac- 4,4’ – Diaminodiphenylmethane (MDA) ture of high-performance polymers, preparation of polyurethane Plasticizer (softener) in PVC, printing inks, paper and Dibutyl phthalate (DBP) packaging coatings, etc… Plasticizer (softener) of PVC, acrylics, sealants, adhe- Benzyl butyl phthalate (BBP) sives, inks, paints, etc.. Plasticiser in polymer products, mainly PVC, blister Bis (2-ethyl(hexyl)phthalate) (DEHP) packing Gas masks, humidity indicator, dye mordant for glass Cobalt dichloride industry, drying agent in paints, lacquers, varnishes and printing inks, etc… custom solutions for compliancy [ reach | rohs | cpsia | rsl | prop65 ]
  11. 11. AS SENTCOM PLIANCEinfo@assentsvhc.com w w w. a s s e n t s v h c . c o m tel: 866.964.6931Lead hydrogen arsenate Insecticides Dying industry, printing, colored glass, insecticide, Diarsenic pentaoxide metallurgy (to harden copper, lead or gold in alloys), etc… Decolorizing agent for glass and enamels, oxidizing Diarsenic trioxide agent special glass and lead crystal formulations, weed killers Metal finishing, aiding corrosion resistance, chrome-Sodium dichromate tanning of leather, colored glass and ceramic glazes5-tert-butyl-2,4,6-trinitro-m-xylene Fragrance, cosmetics and soap perfumes(musk xylene)Hexabromocyclododecane (HBCDD) Flame retardant used in HIPS, PS insulation and and all major diastereoisomers textiles Manufacture of bulk, large scale chemicals. Alkanes, C10-13, chloro (Short Chain Manufacture of rubber products. Used in adhesives, Chlorinated Paraffins) sealants, coatings and paints, thinners, paint remov- ers, polymer preparations and compounds. Biocide, antimicrobial, incorporated into polymers, Bis(tributyltin)oxide flooring, tiles and carpetingcustom solutions for compliancy [ reach | rohs | cpsia | rsl | prop65 ]
  12. 12. AS SENTCOM PLIANCEinfo@assentsvhc.com w w w. a s s e n t s v h c . c o m tel: 866.964.6931Triethyl arsenate Intermediate for semiconductorsAnthracene oilAnthracene oil, anthracene paste,distn. light Manufacture of other substances – anthracene and carbon black. Other: reducing agents in blast furnac-Anthracene oil, anthracene-low es, as components in bunker fuel, for impregnating, Anthracene oil, anthracene paste sealing and corrosion protection.Anthracene oil, anthracene paste,anthracene fraction Production of electrodes – industrial applications. Other: heavy duty corrosion protection, special pur-Pitch, coal tar, high temp. pose paving, manufacture of other substances and the production of clay targets. Synthesis of polyacrylamides (used in various applica- tions, in particular in waste water treatment and paper Acrylamide processing. Other: polyacrylamide gels for research purposes, grouting agents in civil engineering.Aluminosilicate Refractory Ceramic High-temperature insulation for industrial applica-Fibres tions and in fire protectionZirconia Aluminosilicate, Refractory High-temperature insulation for industrial applica-Ceramic Fibres tions and in fire protectioncustom solutions for compliancy [ reach | rohs | cpsia | rsl | prop65 ]
  13. 13. AS SENTCOM PLIANCEinfo@assentsvhc.com w w w. a s s e n t s v h c . c o m tel: 866.964.6931 Production of toluene diisocyanate – used for the manufacture of flexible polyurethane foams. Other: 2,4-Dinitrotoluene gelatinizing-plasticizing agent for the manufacture of explosive mixtures (e.g. forairbags in cars). Plasticiser for nitrocellulose, cellulose ether, polyac-Diisobutyl phthalate (DIBP) rylate, polyacetate dispersions, gelling aid in plastics, lacquers, adhesives, explosive material and nail polish. Manufacturing pigments and dyes, pigment or coat- ing agent (industrial and maritime paint products), Lead chromate embalming/restoring of art products. Other uses: de- tergents and bleaches, photosensitive materials and for the manufacture of pyrotechnic powder. Colouring, painting and coating agent in sectors such as the rubber, plastic and paints, coatings and varnish-Lead chromate molybdate sulphate red es industries. Other Applications – agricultural equip-(C.I. Pigment Red104) ment, vehicles and aircraft as well as road and airstrip painting. Colouring, painting and coating agent in sectors such as the rubber, plastic and paints, coatings and varnish-Lead sulfochromate yellow (C.I.Pigment es industries. Other Applications – agricultural equip-Yellow 34) ment, vehicles and aircraft as well as road and airstrip painting, camouflage and ammunition marking in the defense area.custom solutions for compliancy [ reach | rohs | cpsia | rsl | prop65 ]
  14. 14. AS SENTCOM PLIANCEinfo@assentsvhc.com w w w. a s s e n t s v h c . c o m tel: 866.964.6931 Additive plasticiser and viscosity regulator with flame- retarding properties for acrylic resins, polyurethane, polyvinyl chloride and other polymers. Other appli-Tris(2-chloroethyl)phosphate cations – adhesives, coatings, flame resistant paints and varnishes. Main industries – furniture, textile, building. Common solvent used in surface coatings such as lac-2-Ethoxyethanol quers and paints. Other uses : varnish removers, print- ing inks, duplicating fluids, wood stains, and epoxies. Additive in airplane de-icing solutions. Also used as a 2-Methoxyethanol solvent in varnishes, dyes, and resins. Mordant in dyeing pigments, source of pure nitro- gen in laboratory, manufacturing of chrome alum and Ammonium dichromate alizarin. Other uses: oil purification, leather tanning and pyrotechnics.custom solutions for compliancy [ reach | rohs | cpsia | rsl | prop65 ]
  15. 15. AS SENTCOM PLIANCEinfo@assentsvhc.com w w w. a s s e n t s v h c . c o m tel: 866.964.6931 Antiseptic agent, insecticide, flame retardant, neutron absorber in nuclear power plants, production of glass Boric acid in LCD flat panel displays, ramming mass. Other uses: manufacture of monofilament fiberglass, textile fiberglass, lubricant in carrom boards.Chromic acid Intermediate in chromium plating, colored glass and Oligomers of chromic acid and dichromic ceramic glazes, oxidizing agent, cleaning agent in lab-acid oratory glassware.Dichromic acid Metal finishing, manufacture of wood preservation products, catalyst manufacture, chromium dioxide Chromium trioxide manufacture and pigment manufacture. Other uses: Chrome plating.Cobalt(II) carbonate Pigments in glass, ceramics and paints; catalysts in the Cobalt(II) diacetate petroleum industry especially as paint driers and trace element additives in agriculture and medicine. Other Cobalt(II) dinitrate uses: electroplating, storage batteries, and animal feeds. PET and other plastics for Cobalt (II) diacetate.Cobalt(II) sulphatecustom solutions for compliancy [ reach | rohs | cpsia | rsl | prop65 ]
  16. 16. AS SENTCOM PLIANCEinfo@assentsvhc.com w w w. a s s e n t s v h c . c o m tel: 866.964.6931 Antifungal compound for fiberglass, fire retardant, in- secticide, flux in metallurgy, texturing agent in cook-Disodium tetraborate, anhydrous ing. Other uses: component in detergents, cosmetics, enamel glazes, micronutrient fertilizer. Production of safety matches, inks, explosives, leather Potassium chromate tanning, wood treatment and dyeing textiles. Preparation of chromic acid, manufacture of cement, application in police breathalyzer tests, leather tan-Potassium dichromate ning, in Photography as an oxidizing agent, silver test- ing, wood treatment. Manufacture of chromium compounds, water and al- cohol-based coolants, pigment formulation, mordant Sodium chromate for dyeing wool, wood preservative, oil well drilling fluids and catalysts. Flame retardant in wood, paper, cotton and other Tetraboron disodium heptaoxide, hydrate plant-derived materials.custom solutions for compliancy [ reach | rohs | cpsia | rsl | prop65 ]
  17. 17. AS SENTCOM PLIANCEinfo@assentsvhc.com w w w. a s s e n t s v h c . c o m tel: 866.964.6931 Industrial solvent, coffee decaffeination agent, veg- etable oil extracting agent, volatile gas anesthetic, dry Trichloroethylene cleaning solvent, degreaser for metal parts, manufac- ture of a range of fluorocarbon refrigerants. 2-EEA was used in the past as solvent and intermedi- ate in the chemical industry. It was also used for the formulation of paints, lacquers and varnishes for in- dustrial use. Based on available information, 2-EEA is still used 2-Ethoxyethyl acetate on the EU market, as solvent and for the formulation of paints, lacquers and varnished for professional use exclusively, but at very low volumes. These remain- ing uses are probably very specific, as suggested, for instance, by the following use category: Building and repairing of ships and boats, Manufacture of aircraft and spacecraft.custom solutions for compliancy [ reach | rohs | cpsia | rsl | prop65 ]
  18. 18. AS SENTCOM PLIANCEinfo@assentsvhc.com w w w. a s s e n t s v h c . c o m tel: 866.964.6931 According to the literature and data collected from the consultation, strontium chromate is used by four activity sectors: • formulation of strontium chromate containing mix- tures (coatings such as paints, varnishes, oil-colors, sealants, etc.), • industrial use of strontium chromate containing Strontium chromate formulations (coatings and mixtures) in the aero- nautic/aerospace sector, • industrial use of strontium chromate containing formulations (coatings) in the coil coating sector of steel and aluminum, • industrial use of strontium chromate containing formulations (coatings and mixtures) in the vehicle coating sector.custom solutions for compliancy [ reach | rohs | cpsia | rsl | prop65 ]
  19. 19. AS SENTCOM PLIANCEinfo@assentsvhc.com w w w. a s s e n t s v h c . c o m tel: 866.964.6931 “Based on information from European manufac- turers of phthalates and The European Council for Plasticisers and Intermediates (ECPI), the substance seems not (anymore) to be manufactured in the EU or imported to the EU. DHNUP in Canada is used principally for plasticiser applications and mainly as a 1,2-Benzenedicarboxylic acid, plasticiser to PVC.di-C7-11-branched and linear alkyl esters In Canada, DHNUP is used in polyvinyl chlorides (PVC) and foam; automotive sealant; urethane, glass, and transmission adhesive; roof coatings, barrier coat- ings, exterior trim, and tarps; cement, caulk, and sealer; and high-end luggage. After 2006, the use of DHNUP is mainly in the plasticization of electrical and communication wire insulation.custom solutions for compliancy [ reach | rohs | cpsia | rsl | prop65 ]
  20. 20. AS SENTCOM PLIANCEinfo@assentsvhc.com w w w. a s s e n t s v h c . c o m tel: 866.964.6931 In its hydrated form (in solution concentrations ready for end-use between 3% and 100%): • Synthesis of hydrazine derivatives • These may act as or find uses in products such as pharmaceuticals, agrochemicals, chemical blow- ing agents, paints, inks and organic dyes, reagents for the treatment of nuclear reactor waste, and others (literature provides details of a large range of different applications for derivatives, salts, etc. of hydrazine); • Use as a monomer in polymerisations (mostly for polyurethane coatings and adhesives); use as a corrosion inhibitor in water treatment, mainly for the removal of dissolved oxygen and the adjustment of pH in the feedwater of boilers as well as for the removal of solids from steam genera- tors. The critical areas of application are nuclear and thermal power generation plants (including water steam circulation for district heating and cooling). However, oxygen scavenging based on hydrazine is relevant for other industry sectors that utilise steam such as paper mills, steel manu-Hydrazine facture, production of chemicals. • But not food generation; • Use as a reducing agent in the deposition of metals (nickel, chromium, tin and precious metals) on plastics and glass; • Use as a reducing agent in precious metal and basic metal recovery from metallic salt solutions and effluents; – use as a reducing agent in purification of chemical reagents; • Use as a stabilising agent in aromatic amines (for subsequent paint/ink manufacture); • Use as a laboratory chemical reagent; · in its anhydrous form (at high purity levels, >90%): • Use as a propellant for aerospace vehicles (satellite propulsion and upper stages of satellite launchers); • Use as a fuel in military (emergency) power units (for the F-16 fighter jets); • Use in gas generators for submarine rescue systemscustom solutions for compliancy [ reach | rohs | cpsia | rsl | prop65 ]
  21. 21. AS SENTCOM PLIANCEinfo@assentsvhc.com w w w. a s s e n t s v h c . c o m tel: 866.964.6931 Coatings – High temperature coating, urethane dis- persions, acrylic and styrene latexes. Industrial and consumer cleaners. Paint removers, floor strippers, graf- fiti remover, industrial degreasing, injection head and cast-molding equipment cleaning. Agricultural chem-1-Methyl-2-pyrrolidone icals – Solvent for herbicide, pesticide and fungicide formulations. Electronics Cleaning, de-fluxing, edge bead removal, photoresist stripping. Petrochemical processing. Lube oil processing, natural and synthetic gas purification. Pharmaceuticals Solvent. Today, 1,2,3-TCP is used primarily as a building block for the synthesis of other products, such as: • Pesticides1,2,3-Trichloropropane • Chlorinated solvents • Polysulfide elastomers (cross-linking agent • Hexafluoropropylene (cross-linking agent) approxi- mately 90% is used as an intermediate for conver- sion into other substances.1,2-Benzenedicarboxylic acid, di-C6-8- The main reported uses of DIHP were: · Plasticiser in branched alkyl esters, C7-rich PVC; · Plasticiser in sealants and printing inks.custom solutions for compliancy [ reach | rohs | cpsia | rsl | prop65 ]
  22. 22. AS SENTCOM PLIANCE info@assentsvhc.com w w w. a s s e n t s v h c . c o m tel: 866.964.6931 REACH proposals for addition to the candidate list ec cas substance uses/materials number number Used as solvent, mainly in the manufac- ture of various substances and in the pro- duction of fibres for clothing and other N,N-dimethylacetamide 204-826-4 127-19-5 applications. Also used as reagent, and (DMAC) in products such as industrial coatings, polyimide films, paint strippers and ink removers. Mainly used as initiator or booster in detonators for both civilian and mili- Lead diazide; Lead azide 236-542-1 13424-46-9 tary uses and as initiator in pyrotechnic devices. Mainly used as a primer for small calibre and rifle ammunition. Other common Lead styphnate 239-290-0 15245-44-0 uses are in munition pyrotechnics, pow- der actuated devices and detonators for civilian use. custom solutions for compliancy [ reach | rohs | cpsia | rsl | prop65 ]
  23. 23. AS SENTCOM PLIANCEinfo@assentsvhc.com w w w. a s s e n t s v h c . c o m tel: 866.964.6931 Mainly used as curing agent in resins and in the production of polymer articles and 2,2’-dichloro-4,4’-methyl- 202-918-9 101-14-4 also for manufacture of other substances. enedianiline (MOCA) The substance may further be used in construction and arts. Mainly used as laboratory agent (in pH indicator solutions), for the production Phenolphthalein 201-004-7 77-09-8 of pH-indicator paper and in medicinal products. No registration for this substance has been submitted to ECHA. Lead dipi- crate is an explosive like lead diazide and Lead dipicrate 229-335-2 6477-64-1 lead styphnate. It may be used in low amounts in detonator mixtures togeth- er with the two other mentioned lead compounds. Refractory ceramic fibres are used for high-temperature insulation, almost exclusively in industrial applications Aluminosilicate Refractory (insulation of industrial furnaces and Ceramic Fibres equipment, equipment for the automo- tive and aircraft/aerospace industry) and in fire protection (buildings and indus- trial process equipment).custom solutions for compliancy [ reach | rohs | cpsia | rsl | prop65 ]
  24. 24. AS SENTCOM PLIANCEinfo@assentsvhc.com w w w. a s s e n t s v h c . c o m tel: 866.964.6931 Refractory ceramic fibres are used for high-temperature insulation, almost exclusively in industrial applications Zirconia Aluminosilicate (insulation of industrial furnaces and Refractory Ceramic Fibres equipment, equipment for the automo- tive and aircraft/aerospace industry) and in fire protection (buildings and indus- trial process equipment). Mainly used for manufacture of other 1,2-Dichloroethane; ethylene 203-458-1 107-06-2 substances. Minor uses as solvent in the dichloride chemical and pharmaceutical industry. Mainly used in mixtures for metal surface Dichromium tris(chromate) 246-356-2 24613-89-6 treatment in the aeronautic/aerospace, steel and aluminium coating sectors. Mainly used in coatings in the aeronau-Potassium hydroxyoctaox- 234-329-8 11103-86-9 tic/ aerospace, steel and aluminium coil odizincatedichromate coating and vehicle coating sectors. Mainly used in coatings in the vehi-Pentazinc chromate 256-418-0 49663-84-5 cle coating and aeronautic / aerospace octahydroxide sectors.custom solutions for compliancy [ reach | rohs | cpsia | rsl | prop65 ]
  25. 25. AS SENTCOM PLIANCEinfo@assentsvhc.com w w w. a s s e n t s v h c . c o m tel: 866.964.6931Pentazinc chromate octahydroxide Mainly used for manufacture of other Formaldehyde, oligomeric substances. Minor uses are as hardener reaction products with 500-036-1 25214-70-4 for epoxy resins, e.g. for the production aniline (technical MDA) of rolls, pipes and moulds, and as well for adhesives. No registration for this phthalate com- pound has been submitted to ECHA. Hence, the substance seems not to be Bis(2-methoxyethyl) manufactured in or imported to the EU 204-212-6 117-82-8phthalate in quantities above 1 t/y. Main uses in the past were as plasticiser in polymeric materials and paints, lacquers and var- nishes, including printing inks. Mainly used to remove gas bubbles from ceramic glass melt and for improving ad-Arsenic acid 231-901-9 7778-39-4 hesion between copper foil and resin in the production of laminated printed cir- cuit boardscustom solutions for compliancy [ reach | rohs | cpsia | rsl | prop65 ]
  26. 26. AS SENTCOM PLIANCEinfo@assentsvhc.com w w w. a s s e n t s v h c . c o m tel: 866.964.6931 Calcium arsenate is present in complex raw materials imported for manufacture of copper, lead and a range of precious metals. It appears mainly to be used in Calcium arsenate 231-904-5 7778-44-1 metallurgical refinement processes to precipitate nickel from molten copper and to manufacture diarsenic trioxide. However, most of the substance seems to be disposed of as waste. Trilead diarsenate is present in complex raw materials imported for manufacture of copper, lead and a range of precious metals. The trilead diarsenate contained in the raw materials is in the metallur-Trilead diarsenate 222-979-5 3687-31-8 gical refinement process transformed to calcium arsenate and diarsenic trioxide. Whereas most of the calcium arsenate appears to be disposed of as waste the di- arsenic trioxide is used further.custom solutions for compliancy [ reach | rohs | cpsia | rsl | prop65 ]
  27. 27. AS SENTCOM PLIANCEinfo@assentsvhc.com w w w. a s s e n t s v h c . c o m tel: 866.964.6931 Mainly used in the manufacture of dyes 2-Methoxyaniline; 201-963-1 90-04-0 for tattooing and coloration of paper, o-Anisidine polymers and aluminium foil. Mainly used in the manufacture of poly-4-(1,1,3,3-tetramethylbutyl) mer preparations and of ethoxylates. 205-426-2 140-66-9phenol, (4-tert-Octylphenol) Further used as a component in adhe- sives, coatings, inks and rubber articles. Used primarily as a reaction solvent or process chemical in a wide variety of ap- plications. Used also as solvent for bat-Bis(2-methoxyethyl) ether 203-924-4 111-96-6 tery electrolytes, and possibly in other products such as sealants, adhesives, fu- els and automotive care products.custom solutions for compliancy [ reach | rohs | cpsia | rsl | prop65 ]
  28. 28. AS SENTCOM PLIANCE info@assentsvhc.com w w w. a s s e n t s v h c . c o m tel: 866.964.6931 REACH – COMMON SVHCS DEHP (Bis (2-ethyl(hexyl)phthalate) • Plasticizer in polymer products, mainly PVC, blister packing » In Annex XIV – Sunset Date Feb 21, 2015 » Exemption for uses in the immediate packaging of medicinal products covered under Regulation (EC) No 726/2004, Directive 2001/82/EC, and/or Directive 2001/83/EC. BBP (Benzyl butyl phthalate) • Plasticizer (softener) of PVC, acrylics, sealants, adhesives, inks, paints, etc… » In Annex XIV – Sunset Date Feb 21, 2015 » Exemption for uses in the immediate packaging of medicinal products covered under Regulation (EC) No 726/2004, Directive 2001/82/EC, and/or Directive 2001/83/EC. » Alternatives: custom solutions for compliancy [ reach | rohs | cpsia | rsl | prop65 ]
  29. 29. AS SENTCOM PLIANCEinfo@assentsvhc.com w w w. a s s e n t s v h c . c o m tel: 866.964.6931DBP (Dibutyl phthalate) • Plasticizer (softener) in PVC, printing inks, paper and packaging coatings, etc… » In Annex XIV – Sunset Date Feb 21, 2015 » Exemption for uses in the immediate packaging of medicinal products covered under Regulation (EC) No 726/2004, Directive 2001/82/ EC, and/or Directive 2001/83/EC. » Alternatives:custom solutions for compliancy [ reach | rohs | cpsia | rsl | prop65 ]
  30. 30. AS SENTCOM PLIANCEinfo@assentsvhc.com w w w. a s s e n t s v h c . c o m tel: 866.964.6931Alternatives: DEHP, DBP and BBP are frequently grouped together andtherefore the alternatives overlap• In resilient flooring (DEHP) – plasticizers (assessment from 2005): di (2-eth- ylhexyl) terephthalate (DEHT), di isononyl phthalate (DINP), dipropylene glycol dibenzoate (DGD), and di (2-ethylhexyl) adipate (DEHA). » All proposed alternatives must be assessed for various socio-economic fac- tors; health, environment, technical criteria (are they as effective, as func- tional?) and cost. » 1 of the “alternatives” – DINP - is already regulated under the CPSIA in the US and under the EU Toy Directive however the ECHA conducted a review of new data in July 2010 and did not move forward with any further restrictions on DINPcustom solutions for compliancy [ reach | rohs | cpsia | rsl | prop65 ]
  31. 31. AS SENTCOM PLIANCEinfo@assentsvhc.com w w w. a s s e n t s v h c . c o m tel: 866.964.6931Danish Ministry of the Environment did a fairly heavy alternatives assessment for the three phthalates: abbreviation chemical name cas no.DINCH Di(isononyl) cyclohexane-1,2-dicarboxylate 166412-78-8 Nonylphenol 25154-52-3TXIB Trimethyl pentanyl diisobutyrate 6846-50-0TBAC Tert-butyl acetate 540-88-5 ATBC Acetyl tributyl citrate 77-90-7 DEHTP (same as DEHT) Di(2-ethyl-hexyl)terephthalate 6422-86-2 DINA diisononyl adipate ester 33703-08-1 DEHA Bis(2-ethylhexyl) adipate 103-23-1 DEHS Dioctyl sebacate 122-62-3   Bis(2-ethylhexyl)ester DiBA Diisobutyl adipate 141-04-8 Other non-specified plasticisers custom solutions for compliancy [ reach | rohs | cpsia | rsl | prop65 ]
  32. 32. AS SENTCOM PLIANCE info@assentsvhc.com w w w. a s s e n t s v h c . c o m tel: 866.964.6931 REACH – COMMON SVHCS HBCDD (Hexabromocyclododecane) • Flame retardant used in HIPS (High Impact Polystyrene), PS (Polystyrene) insulation and textiles • In Annex XIV – Sunset Date Aug 21, 2015 • Alternatives: » The ECHA released, in the 2009 report for SVHC List candi- dacy, that there were no suitable alternatives for HBCDD in Expanded or Extruded Polystyrene (EPS and XPS respectively) however there are alternative forms of insulation to be used in place of EPS/XPS. • Mineral wools • Phenolic Foam (not hazardous in itself however the manufacture is hazardous to humans) custom solutions for compliancy [ reach | rohs | cpsia | rsl | prop65 ]
  33. 33. AS SENTCOM PLIANCEinfo@assentsvhc.com w w w. a s s e n t s v h c . c o m tel: 866.964.6931 » There are commercially available alternative fire-retardants avail- able to the use of HBCDD in HIPS and textile coatings, includ- ing non-halogenated flame retardants that provide the same level of fire protection and performance. • Fire retardants in HIPS: Antimony trioxide (ATO), Triphenyl phosphate (Chronic toxicant with effects on liver), Decabromodiphenylether/ATO (Neurotoxicant), Decabrom- odiphenylethane/ATO (Limited data, but likely to be of low toxicity) • Alternatives to HIPS: Polyethylene with Magnesium Hydroxidecustom solutions for compliancy [ reach | rohs | cpsia | rsl | prop65 ]
  34. 34. AS SENTCOM PLIANCE info@assentsvhc.com w w w. a s s e n t s v h c . c o m tel: 866.964.6931 REACH – OTHER NOTES ON SVHCS important note: echa Guidance on svhc documentation “From Article 36(1)12 of the REACH Regulation it follows that downstream users (article pro- ducers are considered also as downstream users under REACH, if they use a substance or mixture in the production of their articles) have to keep available all the information they require to carry out their REACH obligations. But even if it has been identified that no obligations under REACH apply, these companies should consider documenting the results of their compliance checking. This includes documenting the decision-making on whether certain products are articles, substances or mixtures as well as the checking if specific requirements apply for these. Documenting this is recommended to producers and importers of articles in general, as it facilitates demon- strating REACH compliance towards customers and (inspecting/enforcing) authorities.” *Note that the bolded portion above is actually bolded in the Guidance itself to emphasize the importance of Documentation. • The updated “Guidance in a Nutshell” was released at the end of June. • Compact version (17 pages) of the complete guidance document There were no huge changes from the previous guidance that would impact a compliance plan; most of the updates now have to do with further clarity but no large departures in policy. custom solutions for compliancy [ reach | rohs | cpsia | rsl | prop65 ]
  35. 35. AS SENTCOM PLIANCEinfo@assentsvhc.com w w w. a s s e n t s v h c . c o m tel: 866.964.6931REACHauthorisation overview• The Authorisation process – starts with the identification of substances of very high concern (SVHC) by Member State Competent Authorities or the European Chemicals Agency (on behalf of the European Commission) by preparing a dossier in accordance with Annex XV. Decisions on priori- tisation of these SVHCs and the subsequent release of the final list of sub- stances subject to authorisation is decided by the Commission.• Industry has to apply to the ECHA for authorisation for uses of these substances. After an approval process, the holder of an authorisation can use and place on the market the substance for the uses he was granted an authorisation.summaryMost, if not all, substances on the current SVHC List will eventually re-quire an Authorisation for their use on a per substance, per company, per use basis.custom solutions for compliancy [ reach | rohs | cpsia | rsl | prop65 ]
  36. 36. AS SENTCOM PLIANCE info@assentsvhc.com w w w. a s s e n t s v h c . c o m tel: 866.964.6931 REACH the aim of authorisation • As per article 55 of the REACH Regulation: “the good functioning of the internal market while assuring that the risks from substances of very high concern are properly controlled and that these substances are progressively replaced by suitable alternative substances or technologies where these are economically and technically viable”. • All Authorisation applicants shall analyse the availability of alternatives, con- sider their risks, and the technical and economic feasibility of substitution. • If the risk is not adequately controlled, an authorisation may still be granted if it is proven that the socio-economic benefits outweigh the risks and there are no suitable alternative substances or technologies. custom solutions for compliancy [ reach | rohs | cpsia | rsl | prop65 ]
  37. 37. AS SENTCOM PLIANCE info@assentsvhc.com w w w. a s s e n t s v h c . c o m tel: 866.964.6931 REACH authorisation process – substances beinG added to the list Authorisation Process – Annex 15 Dossiers: 1. Registry of intentions – Intention to submit dossier 2. Submission of Annex XV dossier (SVHC Dossier) to ECHA for Compliance Check 3. Publication of Annex XV dossier (once it has passed compliance check) 4. After Commenting periods – Candidate List (Article 33 Requirements kick in) 5. Prioritisation list – Order in which substances will be reviewed for Authorisation 6. Authorisation List – Restrictions and Authorisations handed out custom solutions for compliancy [ reach | rohs | cpsia | rsl | prop65 ]
  38. 38. AS SENTCOM PLIANCEinfo@assentsvhc.com w w w. a s s e n t s v h c . c o m tel: 866.964.6931An Authorisation will contain the following information:• Substance identity• Substance intrinsic properties of very high concern,• Sunset date, date by when a substance can no more be used without authorisation• Application date, date before which an application for authorisation for each use that is not exempted from the authorisation requirement must be made, in order to continue to use the substance for the specific use.• Review period for uses, if appropriate• Exempted uses or categories of usescustom solutions for compliancy [ reach | rohs | cpsia | rsl | prop65 ]
  39. 39. AS SENTCOM PLIANCE info@assentsvhc.com w w w. a s s e n t s v h c . c o m tel: 866.964.6931 REACH – AuTHORISATION process overview – application for authorisation The ECHA published new tools for preparation and submission of Authorisation Applications: http://echa.europa.eu/news/na/201104/na_11_16_authorisation_applications_20110405_en.asp custom solutions for compliancy [ reach | rohs | cpsia | rsl | prop65 ]
  40. 40. AS SENTCOM PLIANCE info@assentsvhc.com w w w. a s s e n t s v h c . c o m tel: 866.964.6931 REACH – AuTHORISATION current authorisation list substance included in annex, sunset date 4,4’ – Diaminodiphenylmethane (MDA) In Annex XIV – Sunset Date Aug 21, 2014 Dibutyl phthalate (DBP) In Annex XIV – Sunset Date Feb 21, 2015 Benzyl butyl phthalate (BBP) In Annex XIV – Sunset Date Feb 21, 2015 Bis (2-ethyl(hexyl)phthalate) (DEHP) In Annex XIV – Sunset Date Feb 21, 2015 5-tert-butyl-2,4,6-trinitro-m-xylene (musk In Annex XIV – Sunset Date Aug 21, 2014 xylene) Hexabromocyclododecane (HBCDD)and In Annex XIV – Sunset Date Aug 21, 2015 all major diastereoisomers identified: custom solutions for compliancy [ reach | rohs | cpsia | rsl | prop65 ]
  41. 41. AS SENTCOM PLIANCE info@assentsvhc.com w w w. a s s e n t s v h c . c o m tel: 866.964.6931 RECOMMENdEd fOR AuTHORISATION recommended for inclusion dec 17, 2010 substances Diarsenic pentaoxide Diarsenic trioxide Alkanes, C10-13, chloro (Short Chain Chlorinated Paraffins) 2,4-Dinitrotoluene *Recommendation for inclusion June 1, 2009 Diisobutyl phthalate (DIBP) Lead chromate Lead chromate molybdate sulphate red (C.I. Lead sulfochromate yellow (C.I.Pigment Yellow 34) Pigment Red104) Tris(2-chloroethyl)phosphate *SCCPs are already included in the Convention on Long- Range Transboundary Air Pollution and triggers additional obligations under Regulation (EC) No 850/2004 – if further information is required, please contact Assent. custom solutions for compliancy [ reach | rohs | cpsia | rsl | prop65 ]
  42. 42. AS SENTCOM PLIANCE info@assentsvhc.com w w w. a s s e n t s v h c . c o m tel: 866.964.6931 dRAfT RECOMMENdATION fOR AuTHORISATION comment deadline sept 14th substances Cobalt dichloride Sodium dichromate Ammonium dichromate Chromic acid Oligomers of chromic acid and dichromic Dichromic acid acid Chromium trioxide Cobalt(II) carbonate Cobalt(II) diacetate Cobalt(II) dinitrate Cobalt(II) sulphate Potassium chromate Potassium dichromate Sodium chromate Trichloroethylene custom solutions for compliancy [ reach | rohs | cpsia | rsl | prop65 ]
  43. 43. AS SENTCOM PLIANCE info@assentsvhc.com w w w. a s s e n t s v h c . c o m tel: 866.964.6931 wHAT dOES AuTHORISATION MEAN fOR yOu? If a substance within your products is on the Authorisation list: • Testing and/or creation of testing proposals • Possible creation of a new CSR • Analysis of Alternatives • Substitution Plan • Socio-Economic Analysis Time, Expense and Expertise is required and the authorisation may not even be granted. Furthermore, the authorisation has a set time limit; a review re- port must be submitted at least 18 months before its expiry. Is there another option? • Redesign ensures that no authorizations have to be submitted. custom solutions for compliancy [ reach | rohs | cpsia | rsl | prop65 ]
  44. 44. AS SENTCOM PLIANCE info@assentsvhc.com w w w. a s s e n t s v h c . c o m tel: 866.964.6931 REACH INTERPRETATION france forGes a new path • ECHA guidance has maintained that complex articles will be enforced upon “as imported” or “as manufactured” and therefore each component of the article is not assessed against the 0.1% w/w threshold individually. France has disagreed with this interpretation since the first guidance on substances in articles was published by the ECHA. • France will be enforcing the 0.1% threshold for content of SVHCs (Substances of Very High Concern) based on the “once an article, always an article approach”. • Each component is an article before being incorporated into another article thus the “once an article, always an article” approach. • Austria, Belgium, Denmark, Germany, Sweden (and Norway, not a member state but follows REACH) have yet to officially publish an enforcement policy contrary to the ECHA but have also made it clear that they do not prescribe to the ECHA’s article interpretation. • There are many long and formal steps that need to be taken by the ECHA before an infringement case is even brought against France before the EU court therefore it cannot be assumed that this will be resolved so that all Member states are working with the same “ECHA interpretation”. custom solutions for compliancy [ reach | rohs | cpsia | rsl | prop65 ]
  45. 45. AS SENTCOM PLIANCE info@assentsvhc.com w w w. a s s e n t s v h c . c o m tel: 866.964.6931 IMPACT Of fRANCE’S ENfORCEMENT POLICy Companies importing to the EU cannot weigh their SVHC content against the whole complex article. • Each component must have SVHC data – content % and weight of the component • Declarations must be updated • 2 versions – one for France, one for the rest of the EU • 1 version that contains all the necessary information • Astronomical increase in testing costs OR • Supplier data gathering and engineering assessments even more vital • Data exponentially increases • Storage and organization paramount custom solutions for compliancy [ reach | rohs | cpsia | rsl | prop65 ]
  46. 46. AS SENTCOM PLIANCE info@assentsvhc.com w w w. a s s e n t s v h c . c o m tel: 866.964.6931 REACH IS wORkINg • REACH Regulation requires a report at least every 5 years on the overall status of the Regulation • This report will provide information on where all stakeholders (but mostly the ECHA) can improve • First report released July 1, 2011 and reports on REACH and CLP. • Examines the lessons and challenges encountered so far (3 years into REACH, 2 years into CLP). • Deals with everything from nanomaterials to joint registration to IT tool support custom solutions for compliancy [ reach | rohs | cpsia | rsl | prop65 ]
  47. 47. AS SENTCOM PLIANCEinfo@assentsvhc.com w w w. a s s e n t s v h c . c o m tel: 866.964.6931summary:• Communication and feedback to all REACH stakeholders – registrants, third- party contributors, helpdesk representatives – should improve which should speed up responses and guidance.• REACH processes and Comitology should improve which will speed up SVHC additions, authorisation additions along with the aforemention guid- ance updates• Enforcement guidance and processes will hopefully be further specified (joint registration in particular)custom solutions for compliancy [ reach | rohs | cpsia | rsl | prop65 ]
  48. 48. AS SENTCOM PLIANCE info@assentsvhc.com w w w. a s s e n t s v h c . c o m tel: 866.964.6931 REACH IS wORkINg – REPORT dETAILS • Further clarification is required around nanomaterials and how REACH and CLP will apply • European Commission (EC) and Member State Competent Authorities (MSCAs) should focus some energy on enforcement surrounding the joint registration requirement • It was even suggested that consideration should be given to changing the legal text to aid in enforcement • Intermediates registration dossiers need to be brought into full compliance – two-sided issue: regulatory action AND industry pro-actively reassess and updating if necessary. • Dormant pre-registrations should be deleted, Companies not intending to register their pre-registered substances should deactivate themselves. Optimize the use of pre-SIEFs custom solutions for compliancy [ reach | rohs | cpsia | rsl | prop65 ]
  49. 49. AS SENTCOM PLIANCEinfo@assentsvhc.com w w w. a s s e n t s v h c . c o m tel: 866.964.6931• Many points on the ECHAs need to improve support and feedback (both timing and content) for: third party contributions for examination of test- ing proposals, use of IT tools, legal interpretations of outstanding issues from the “Helpdesk” submissions.• REACH process reviews as well as the efficiency of the Committees and Forums associated with REACH.custom solutions for compliancy [ reach | rohs | cpsia | rsl | prop65 ]
  50. 50. AS SENTCOM PLIANCE info@assentsvhc.com w w w. a s s e n t s v h c . c o m tel: 866.964.6931 REACH enforcement – echa enforcement plans for the future • Swedish Chemicals Agency announced the ECHA’s intention to submit an enforcement plan to the Ministry of the Environment at the end of 2011.Enforcement project will begin in 2012 http://www.kemi.se/templates/News____6284.aspx • Previous enforcement process will likely be applied to SVHCs • European-wide coordination • Local level implementation • REACH-IT used by local inspectors to coordinate and verify information • Information must be accurate, transparent and readily available custom solutions for compliancy [ reach | rohs | cpsia | rsl | prop65 ]
  51. 51. AS SENTCOM PLIANCEinfo@assentsvhc.com w w w. a s s e n t s v h c . c o m tel: 866.964.6931Implement your compliance scheme in accordance with available Guidance in order to protect yourself in the future.An ECHA REACH and CLP Enforcement and Appeals Workshop is planned for October 15th, 2011. Brainstorming sessions on enforcement, discussion on the real issues surrounding enforcement as well as learning about the ap-peals process with the ECHA are all on the agenda for this event. As a result, we should see quite a bit of information and clarity on processes being released.custom solutions for compliancy [ reach | rohs | cpsia | rsl | prop65 ]
  52. 52. AS SENTCOM PLIANCE info@assentsvhc.com w w w. a s s e n t s v h c . c o m tel: 866.964.6931 REACH enforcement – danish consumer council • Danish NGO representing the interest of Danish Consumers http://www.forbrugerraadet.dk/english/ • Sent REACH requests to retailers across Denmark • 40% replied in compliance with REACH • 60% either responded late or not at all • All late respondents were reported to the Danish EPA Keys to a quick response: • Restricted Substance Control policy • Availability of internal documentation custom solutions for compliancy [ reach | rohs | cpsia | rsl | prop65 ]
  53. 53. AS SENTCOM PLIANCE info@assentsvhc.com w w w. a s s e n t s v h c . c o m tel: 866.964.6931 REACH enforcement – mobilization of etuc and emcef • ETUC (European Trade Union Confederation) and the EMCEF (European Chemical Workers’ Federation) • Alerting their member organizations to alert employers to their responsi- bilities under REACH. • Ensures worker safety • Ensures continued business • Leaflet being prepared • Full endorsement of the ECHA REACH violations are a potential worker health and safety issue. custom solutions for compliancy [ reach | rohs | cpsia | rsl | prop65 ]
  54. 54. AS SENTCOM PLIANCE info@assentsvhc.com w w w. a s s e n t s v h c . c o m tel: 866.964.6931 REACH MEMBER STATE ENfORCEMENT PENALTIES member state penalty Belgium Fines up to $5,385,000 – Imprisonment up to 3 years France Fines up to $100,000 – Imprisonment up to 2 years Germany Fines up to $135,000 – Imprisonment up to 5 years Ireland Fine up to $4,000,000 – Imprisonment up to 2 years Netherlands Fines up to $900,000 – Imprisonment up to 6 years United Kingdom No limit on Fines – Imprisonment up to 2 years custom solutions for compliancy [ reach | rohs | cpsia | rsl | prop65 ]
  55. 55. AS SENTCOM PLIANCE info@assentsvhc.com w w w. a s s e n t s v h c . c o m tel: 866.964.6931 REACH ENfORCEMENT – IMPACT Stoppage at Customs is the most likely action for SVHC issues: • Risk to business continuity • Loss of customers • Loss of expected product launch timelines • Risk of financial penalty NGO involvement will increase • More media, more attention = more enforcement, more risk to non-compliant businesses Standardized enforcement across the EU • “Quotas” will be established so all member states will be enforcing in order to ensure safety is a priority across the EU custom solutions for compliancy [ reach | rohs | cpsia | rsl | prop65 ]
  56. 56. AS SENTCOM PLIANCE info@assentsvhc.com w w w. a s s e n t s v h c . c o m tel: 866.964.6931 PRACTICAL APPLICATION ideal Qualities of a declaration of conformity • A declaration should ideally be part of a process that keeps all your information current and your declarations consistent. • Upon request, you should be able to show the following items: • Who sent the declaration (person, not just company) » What was the exact response » When was it sent » How (email, ftp, snail mail) • What was asked of the supplier on the Declaration » When » How • How these declarations are stored • How they are verified • How/When they are updated custom solutions for compliancy [ reach | rohs | cpsia | rsl | prop65 ]
  57. 57. AS SENTCOM PLIANCE info@assentsvhc.com w w w. a s s e n t s v h c . c o m tel: 866.964.6931 TyPICAL SERVICE OffERINgS rohs reach component enGineers • Manage the compliance to ROHS, REACH SVHC, and JIG Level A/B standards • Ensure compliance with regulatory agencies and compliance regulations, including RoHS, REACH, and WEEE. • Review and evaluate RoHS / WEEE requirements and requirement changes as published by regulating bodies • Supporting sourcing and selection of electronic and mechanical components • Serve as subject matter expert on regulatory matters • Mentoring / support of engineering team on compliance issues • Specification and drawing review for compliance • Obsolescence management and part substitution • WEEE registration and reporting • Work with suppliers on corrective actions • More experience and less cost than hiring a full time component engineering custom solutions for compliancy [ reach | rohs | cpsia | rsl | prop65 ]
  58. 58. AS SENTCOM PLIANCE info@assentsvhc.com w w w. a s s e n t s v h c . c o m tel: 866.964.6931 ROHS ANd REACH component and product enGineerinG services • On demand product and component engineering services • Specializing in a wide range of compliance requirements including RoHS, WEEE, REACH, UL, CSA, ETL, FCC, NOM, and Proposition 65. • All component engineers have a minimum of 5 years of RoHS/ REACH experience • On call, part time, and full time contact support available. custom solutions for compliancy [ reach | rohs | cpsia | rsl | prop65 ]
  59. 59. AS SENTCOM PLIANCE info@assentsvhc.com w w w. a s s e n t s v h c . c o m tel: 866.964.6931 QuESTIONS? Please submit your questions in writing using the Q&A tool along the top menu tool bar. Any questions not addressed during the Q&A portion of this webinar will be addressed in private correspondence after the webinar. custom solutions for compliancy [ reach | rohs | cpsia | rsl | prop65 ]

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