Guys,
?
There is a parallel discussion on REACH on IPC's ComplianceNet.? There, John Sharp, now of Triquint Semiconductor, has been posting the very latest REACH updates (three more SVHC's yesterday in addition to the 15 last week).?? Here is John's posting to my question about what happens when a SVHC is a component of a polymer.? Please note John's disclaimer to be an expert.?
?
For me, the good news is that people ARE talking before deadlines arrive, and John lead two comment groups that fought Gallium Arsenide, and Antimony Trioxide.? An aside - the French are the ones who proposed gallium arsenide, and now yesterday threw in tetrohydrofuran (THF).? The source I looked up regarded THF as "relatively safe - about like acetone".? Anyone know who submits the French SVHC candidates?? Or are the French smoking something that is an SVHC?
?
Here is John's posting:
-----Original Message-----
From: Sharp, John <[log in to unmask]>
To: [log in to unmask]
Sent: Tue, Sep 1, 2009 4:11 pm
Subject: Re: [CN] FW: Press Release: New public consultation on 15 potential Substances of Very High Concern
Denny,
I definitely do not claim to be a REACH expert, but I will try to answer
the question. Remember that this advice is worth every penny you are
paying for it! Definitely check my answers with those of some REACH
experts.
IF ANYONE SEES ERRORS IN MY ANSWER AND WANTS TO CORRECT IT, PLEASE DO SO
IN A REPLY BACK TO THE COMPLIANCENET LISTSERV!
There are a lot of subtleties to the answer to your question. If we are
only talking about the unreacted monomer in a polymer, that is one
thing. However, if we are talking about an unreacted monomer that is an
intermediate, that is another thing.
+++++++++++++++++++++++
First, let's look at the unreacted monomer in a polymer.
Let's assume that you have already figured out the Notification and
Registration requirements that are listed in the following two
paragraphs.
If the monomer is 2% or more by weight of the polymer AND you import
more than 1 tonne per year of the unreacted monomer into the EU, you
have to register the monomer with the ECHA if another actor up the
supply chain has not already registered the monomer (Article 6.3).
Assuming that the unreacted monomer is less than 2% of the polymer by
weight, AND you import less than 1 tonne per year OR it is not intended
to be released from the articles, it isn't subject to the Registration
requirements of Article 7. If you import more than 1 tonne per year AND
the unreacted monomer is present in the article above a concentration of
1000 ppm and the monomer is identified as an SVHC (Article 57), then you
are subject to the Notification requirement of Article 7.
So in my opinion, if the unreacted monomer that is identified as an SVHC
has a concentration of 1000 ppm or less in the article, then it is okay
to be in that article (regulatorily speaking! Customers may have a
different opinion). The material becomes an article once its form or
shape becomes more important to its function than its composition is.
So in the foam rubber, if the shape is more important for the job of
cushioning than the compositi
on of the foam rubber, then the foam rubber
is an article, and the 1000 ppm concentration limit applies.
++++++++++++++++++++++++
Second, if we are talking about an intermediate:
How the unreacted monomers will be treated depends on whether they are
"iso-lated" or "non-isolated", and to what extent they are contained in
the final product or article. REACH defines these terms as (REACH text
in quotes):
"Intermediate: means a substance that is manufactured for and consumed
in or used for chemical processing in order to be transformed into
another substance (hereinafter referred to as "synthesis"):
(a) non-isolated intermediate: means an intermediate that during
synthesis is not intentionally removed (except for sampling) from the
equipment in which the synthesis takes place. Such equipment includes
the reaction vessel, its ancillary equipment, and any equipment through
which the substance(s) pass(es) during a continuous flow or batch
process as well as the pipework for transfer from one vessel to another
for the purpose of the next reaction step, but it excludes tanks or
other vessels in which the substance(s) are stored after the
manufacture;
(b) on-site isolated intermediate: means an intermediate not meeting the
criteria of a non-isolated intermediate and where the manufacture of the
intermediate and the synthesis of (an)other substance(s) from that
intermediate take place on the same site, operated by one or more legal
entities;
(c) transported isolated intermediate: means an intermediate not meeting
the criteria of a non-isolated intermediate and transported between or
supplied to other sites;"
If the intermediate is "non-isolated", then REACH doesn't apply (Article
2 - 1.c.) I would qualify this by adding "as long as the intermediate
is not present in the article at a concentration >1000 ppm.
"On-site" and "transported" intermediates are exempt from the
Registration and Notification requirements in Articles 5, 6, and 7.
Articles 8 (only representative of a non-Community manufacturer) and 9
(Product a
nd Process Oriented R&D) do apply. These intermediates are
also exempt from Title VII, which is Authorization. However, "on-site
isolated" intermediates are subject to the Registration requirements of
Article 17, and the data submission requirements of Article 19.
"Transported" intermediates are subject to the Registration requirements
of Article 18.
If the intermediate is "on-site isolated", a Member State may request
more information regarding the risks (Article 49). "On-site"
intermediates are not subject to the Restrictions process in Article 68
(Annex XVII).
+++++++++++++++++++++++++++++
I hope this helps. I probably gave you more than you needed or wanted.
As I said above, I am not an expert on REACH. I am trying to learn
more, but it is an enormous and confusing regulation.
John Sharp
Corporate Product Compliance Manager
TriQuint Semiconductor, INC.
2300 NE Brookwood Pkwy
Hillsboro, OR 97124
503-615-9712
[log in to unmask]
-----Original Message-----
From: ComplianceNet [mailto:[log in to unmask]] On Behalf Of Dennis
Fritz
Sent: Tuesday, September 01, 2009 11:34 AM
To: [log in to unmask]
Subject: Re: [CN] FW: Press Release: New public consultation on 15
potential Substances of Very High Concern
John,
Di nitro toluene is on the list.? That is an intermediate in making
about a third of the iscyanates - especially the flexible - "foam
rubber".?? Do you know how the EU will regulate traces of un-reacted
monomers in plastics?? Also, as this is an intermediate, will its
manufacture be restricted??? The list I saw last year of hundreds of
"substittute it now - SIN" chemicals had most of the intermediates for
all kinds of polymers - epoxy, ABS, PVC etc.? This could set a precident
for the intermediates in those.?
Denny Fritz
-----Original Message-----
From: Sharp, John <[log in to unmask]>
To: [log in to unmask]
Sent: Tue, Sep 1, 2009 11:10 am
Subject: [CN] FW: Press Release: New public consultation on 15 potential
Substances of Very High Concern
Compliance Netters,
More potential S
VHCs for REACH. I don't see anything that raises
alarms, but maybe the acrylamide and the two ceramic fibers are more
prevalent than I am thinking.
John Sharp
Corporate Product Compliance Manager
TriQuint Semiconductor, INC.
2300 NE Brookwood Pkwy
Hillsboro, OR 97124
503-615-9712
[log in to unmask]
________________________________
From: ECHA Press Room [mailto:[log in to unmask]]
Sent: Tuesday, September 01, 2009 5:13 AM
To: ECHA Press Room
Subject: Press Release: New public consultation on 15 potential
Substances of Very High Concern
Please find below a link to the European Chemicals Agency's Press
Release ECHA/PR/09/12 of 1 September 2009: New Public consultation on 15
potential Substances of Very High Concern (SVHC).
http://echa.europa.eu/doc/press/pr_09_12_second_consultation_svhc_identi
fication_20090901.pdf
Best Regards,
ECHA Press
-----Original Messageto TechNet-----
From: Douglas Pauls <[log in to unmask]>
To: [log in to unmask]
Sent: Wed, Sep 2, 2009 4:01 pm
Subject: [TN] Teflon and SVHCs
Good afternoon all,
Being a glutton for punishment and a real slow learner (leave it alone
Dewey), I find myself on our Corporate REACH team. Before going off to do
an afternoon of googling, does anyone know:
a. is there a good central location on polymeric materials and their
constituent materials?
b. Do you know if Teflon contains any of the current substances of very
high concern (SVHCs)?
I know that polymers are exempt from Registration, but not from reporting.
Thanks.
Doug Pauls
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