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December 2009

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From:
Gene Felder <[log in to unmask]>
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Date:
Tue, 15 Dec 2009 10:44:10 -0800
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I did some searching on the Internet and found:

http://www.synapsistech.com/eu-reach/index.html 

 

It includes: "On October 28th, 2008, the European Chemicals Agency (ECHA)
published the first Candidate List of Substances of Very High Concern
(SVHCs). This list of 15 hazardous substances is expected to grow to 1,000
or more substances in the years ahead."

 

I think they are focusing on pesticides, etc.  So for a REACH statement from
a company selling electronics, we have received from our suppliers
(including large companies with legal departments) and send to our customers
letters including the following language:

Re: European Regulation REACH 1907/2006/CE (Registration, Evaluation and
Authorization of Chemicals) 

This material should be considered an "article" under the REACH guidelines.
It does not "contain substances intended to be released under normal or
reasonably foreseeable conditions of use". As such, there is no obligation
for registration or notification under the REACH Directive.

 

Furthermore, none of the substances listed as "Substances of Very High
Concern" (SVHC) are intentionally added in manufacturing.

 

The product composition information is to the best of our knowledge and may
be based on third party supplier information and/or our knowledge and
experience regarding typical substance composition found in materials used
in ESD control products.

 

Then we link to our Limited Warranty, noting that it says "only obligation
shall be to replace such quantity of the product proved to be defective."

 

 

Gene Felder

[log in to unmask] 

 

 

-----Original Message-----
From: TechNet [mailto:[log in to unmask]] On Behalf Of Douglas Pauls
Sent: Tuesday, December 15, 2009 10:00 AM
To: [log in to unmask]
Subject: Re: [TN] Cliff Notes for REACH

 

Phil,

In short, there is no Cliff Notes version for REACH, no short, easily 

comprehensible, straightforward guide for us in the electronics industry. 

The European Chemicals Agency (ECHA) has published a number of guidance 

documents, but none of them short or easy.

 

Your best bet is to find someone else in your company that you either 

really really hate or who is really really gullible, and have them be your 

REACH person.  Of course, if you do that, you will eventually be the 

person that someone really really hates.

 

Doug Pauls

 

 

 

Phil Nutting <[log in to unmask]> 

Sent by: TechNet <[log in to unmask]>

12/15/2009 11:36 AM

Please respond to

TechNet E-Mail Forum <[log in to unmask]>; Please respond to

Phil Nutting <[log in to unmask]>

 

 

To

[log in to unmask]

cc

 

Subject

[TN] Cliff Notes for REACH

 

 

 

 

 

 

OK, I'm coming into this late and I am totally unprepared.  That said, is 

there a good guideline in layman's terms of what we will need to do for 

our high voltage power supplies

 

Thanks in advance.

 

Phil Nutting

 

Note: All the information contained in this e-mail and its attachments is 

proprietary to Kaiser Systems, Inc. and it may not be reproduced without 

the prior written permission of sender.  If you have received this email 

in error, please immediately return it to sender and delete the copy you 

received.

 

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