A presentation given by ReAgent's Systems Manager, Graham Bayliss. The presentation was given at an event run by Chemicals Northwest in Runcorn. It discusses how REACH impacts at ReAgent and other ways it is used in industry.

1. REACH PRESENTATION
The Heath
Wed 4th June

2. • Graham Bayliss
• Reagent Chemical Services Ltd trades under
the brand of Reagent
• SME of approx. 30 employees
• Based on Whitehouse Industrial Estate in
Runcorn
Introduction

3. • Founded by Derek Millard and his wife Norma in 1979.
• Ex ICI employee who bought out the old Standards Laboratory
at Winnington, Northwich.
• Initially local business, mainly ICI.
• Developed into multi-million pound turnover.
• ReAgent is now in the third generation of management.
• Recent success due largely to website and e-commerce.
Company History

4. • Core business is chemical blending
• Highly accurate standard solutions and general chemical
reagents
• Strength is flexibility to manufacture bespoke products to
customers individual needs.
• Supply automotive, aerospace, pharmaceutical industry and
MoD
• Batch manufacture size from millilitres to several thousand
litres.
• Facilities to fill sachets and ampoules
What services Does ReAgent Offer?

5. Certification
• ISO 9001 Quality Standard
• ISO 14001 Environmental Standard
• Investors in People
• Working towards OHSAS 18001
• Home Office and Local Authorities

6. My Role at ReAgent
• Trainee laboratory technician progressed to supervisory and
managerial roles
• Part-time study to achieve MRSC CChem status
• Works Manager then switched to Quality Manager
• Systems Manager responsible for QHSE management systems
to ISO standards, compliance with relevant legislation and
Investors in People.
• Implementation of new EU legislation, CLP 1272/2008 and of
course REACH.

7. How Does REACH Affect ReAgent?
• We are a Downstream User (DU)
• Not classed as a manufacturer so no duty to register products
• NOT REMOVED FROM DUTIES UNDER REACH
• Supply of information up and down the supply chain
• Only use substances registered with our intended uses
• Provision of Safety Datasheets (SDS) with our products
• Ensure supplier SDS are made available to all who need them
• Implement the necessary Risk Management Measures

8. How Does ReAgent Comply?
• Identification of all raw material suppliers and notification of
our intended uses with standard Descriptor Codes.
• All supplier details are held on company intranet system
• Only REACH compliant companies are used
• Simple questionnaire to identify compliance
• Safety Datasheets are generated from software linked to the
product classification
• Consider restrictions on use and SVHC’s

9. Problems Meeting Compliance
• Time and resources
• Fitting in between other responsibilities
• FAILURE TO COMPLY IS NOT AN OPTION
• Label classification and SDS generation
• Finding sources of information
• Communication within the business
• Maintaining awareness of the directors when making future
business decisions
• Integration with other legislation, CLP etc
• Consistency between information sources

10. Effects of CLP on ReAgent
• Impact has been as big if not greater than REACH
• Several hundred products to be re-classified by June 2015
• Large changes to label design and SDS format
• REACH and CLP legislation is massive and time consuming to
understand
• Increase in the amount of hazard categories
• Choice of most appropriate P statements
• Under new classification criteria there are potentially more
products that will be classed as hazardous.
• Effect on transportation costs eg. Corrosive products.

11. Information Sources and Inconsistency
• In theory REACH and CLP (GHS) are designed to achieve
consistency, in practice still far from this
• Available sources of Information
Supplier SDS
ECHA website
ESIS (European Substances Information System) website
The CLP Regulation
• If the theory worked then all the above would agree, however
this is not the case
• Substance classifications can differ between a) Suppliers
b) Suppliers and ECHA c) ECHA and ESIS
• The CLP Regulation only contains Partial classifications

12. Information Sources and Inconsistency
• Headache for SDS compilation, especially mixtures
• Which one is correct?
• Under REACH downstream users must compile their SDS and
classify products on information received from suppliers.
• Discrepancies can be passed further down the supply chain
• Personal experience has indicated the greatest potential for
difference is in self classification from set criteria

13. Information Sources and Inconsistency
• Tin Dichloride Dihydrate or Stannous Chloride
• Supplier
H314 – Causes severe skin burns and eye damage
• ECHA
H315 – Causes skin irritation
H317 – May cause an allergic reaction
H319 – Causes serious eye irritation
H332 – Harmful if inhaled
H335 – May cause respiratory tract irritation
H341 – Suspected of causing genetic defects
H361 – Suspected of damaging fertility or the unborn child
H373 – May cause damage to organs
H410 – Very toxic to aquatic organisms with long lasting effects

14. Information Sources and Inconsistency
• Third party supplier
H302 – Harmful if swallowed
H314 – Causes severe skin burns and eye damage
Toxicological and Ecotoxicological Data
• Required for sections 11 and 12 of the SDS
• Again information can be different between suppliers and ECHA
• Which do we use?
• ECHA score data with a reliability rating of 1 to 4
• Should use supplier data but ECHA often has information quoted
with a lower LD50 value – more appropriate?

15. Information Sources and Inconsistency
• SDS Format
Many are still in the older format
Incomplete
Include the statement ‘No information available’
• The whole process of classification and SDS generation can be
difficult and confusing
• Contradicts what it sets out to achieve

16. Overcoming Problems of REACH and CLP
• Unfortunately there is no easy answer
• Generic e-mail sent to all suppliers with intended uses and
check our sales to customers were for registered uses
• Product classification and SDS generation assisted by software
• This must be updated and installed before June 2015
• Best to classify from scratch applying the new criteria rather
than use the translation table
• Software manufactures have released a new package but it
comes at a price
• IT staff have helped to design new label templates
• Training has been a key issue throughout the business
• Several hundred products have been removed
• Where possible generic SDS are used

17. Do SDS serve their purpose?
• Probably not taken as seriously in the past
• Since introduction of REACH this appears to be changing
• More customers actually question the content than in the
past
• The answer must be ‘Yes’
• This places pressure on the authors to get information correct
• Risk assessments rely on their content
• Misleading information may have serious consequences

18. Future Outlook and Conclusion
• NO OPTION BUT TO COMPLY – TIME, MONEY AND EFFORT
• ReAgent will continue to introduce new products and remove
those that are uneconomical
• To achieve consistent information transfer I estimate about 10
years
• Exposure scenarios are currently very limited and will need to
be included as part of the SDS
• REACH and CLP must be good for the chemical industry but
can be a real burden
• Our own SDS will need to be constantly updated as more
Registration Numbers become available

19. Future Outlook and Conclusion
• In the short-term REACH will be costly and a drain on
resources
• With threats of prosecution and damage to company image
pressures to comply increase
• In the long-term REACH can only be beneficial to us all for
identification of chemical hazards

20. Contact Us
For more information about ReAgent, please visit
www.ReAgent.co.uk
We’d love to hear from you. Send us an email at
enquiries@reagent.co.uk or call us on 0800-9555-798