Frank Jones runs a small business, Super Sealants, employing around 25 people, producing sealing materials (e.g. gaskets) for a range of applications. The processes used by Frank’s company require a number of chemicals as base starting materials and these are mixed in various proportions to produce the range of sealing products.
Frank became aware, through his customers, of a REACH. He believed that this is all to do with the chemical industry and is not for his sort of business. However, because of questions from his customers, he decided he should find out more and so he read an article about REACH in a trade journal. Frank realised that REACH could have an important effect on his business as all the starting materials he uses are covered by this legislation. He was concerned that he might find it difficult to get supplies of some of them in the future.
Frank decided that he needed to look more closely at the situation. He read more about REACH on the UK REACH Competent Authority website. He realised that as he only buys his ingredients from suppliers who are based in Europe, in fact most based in the UK, he is considered as a downstream user under REACH. However, he also understands that he will only be able to get chemicals in the future that have been at least pre-registered by someone up his supply chain (a manufacturer or importer). He also needs to be sure that his supplier is aware of what he is using these chemicals for so that they are covered by the registration.
So, Frank compiled a list of all the ingredients he uses to make his company’s range of products and who supplies them. Most of what his company uses has been used for many years by Frank and others in his industry to make these kinds of sealant materials. Because of this and from the information he has available he is reassured that these will probably still be supplied and that people up the supply chain know that they are used this way and will cover this use when they register.
However, Frank’s company uses a novel ingredient, a blue pigment, in a small range of their products that are not normally used for producing sealing materials. Frank is not sure if these will be registered or even pre-registered. He therefore decided to contact the supplier of this ingredient. After making enquiries, Frank found that the ingredient were pre-registered, as it is used widely in other sectors, and that now the supplier knows of this specialised use it will be included as part of the registration information in due course. The supplier indicated that they would get back in touch with Frank once they start compiling the registration dossier so that they can find out more information from him on how it is used and possible exposure.