JL Chemicals is a EU based chemical company with sites in Liverpool and Spain. They manufacture chemicals at their site in Liverpool in quantities over 1 tonne per annum, which are transported to their sister site in Spain for subsequent use. The regulatory affairs manager of the Liverpool site, Peter, has read on the internet about REACH and realised that his company will be affected by it. To gain some further knowledge, Peter attended a seminar hosted by his trade association.
On the basis of the information he received at the seminar, Peter looked at all the chemicals manufactured on his site and compiled an inventory. JLChemicals Ltd is primarily involved in the production and supply of intermediates. He looked up the definition for an intermediate in his copy of REACH, and applied this to one of his production processes. This production begins with chemical A, which is manufactured specifically for the synthesis of chemical B. Peter noted that chemical A meets the criteria for an on-site isolated intermediate which, when he checked in the REACH text, has to be registered. However, as chemical A is manufactured and used at JLChemical’s Liverpool site under strictly controlled conditions there are reduced requirements for this type of intermediate.
The final product, chemical B, is then removed from the reactor vessel and is transported on to JLChemical’s Spanish site for use there. Peter worked out that chemical B is a transported isolated intermediate which, when he checked have reduced registration requirements under REACH. However, to qualify for these reduced requirements Peter firstly had to get confirmation from the Spanish site that chemical B will be used in the strictly controlled conditions specified in REACH. Peter contacted his colleague in Spain, Xavier, to gain this confirmation. When discussing this Xavier pointed out that as chemical B is present on EINECS the substance can benefit from a phase-in under REACH and that Peter should pre-register chemical B.
Once Peter had gone through the production of one of his company’s chemicals, he looked at all the production processes at the Liverpool site ensuring that the company did everything they needed to and pre-registered the relevant chemicals during the pre-registration period in 2008.
