Under REACH \[VO (EG) 1907/2006], the companies of the BrüggemannGroup (designated here as BRÜGGEMANN) take on the roles of manufacturer, importer, and also the role of downstream user.
The product portfolio has not changed, even after the 2018 registration period, due to the effects of the REACH regulation.
All substances and raw materials requiring registration in the BRÜGGEMANN product portfolio in 2010 (phase I), 2013 (phase II) and 2018 (phase III) were registered by BRÜGGEMANN or by the relevant suppliers in good time.
The registration numbers of substances classified as hazardous are specified in the safety data sheets.
For other substances information is made available in accordance with Article 32 of the REACH Regulation.
The European Chemicals Agency ECHA has drawn up a list of substances of very high concern (SVHC). This SVHC list is updated about every 6 months. Substances included on this list include CMR substances in categories 1A and 1B, PBT and vPvB, and endocrine disruptors. SVHC substances are candidates for an approval or restriction procedure under the REACH Regulation.
If a product contains an SVHC substance above the consideration limit, BRÜGGEMANN will immediately comply with the obligation to communicate as stipulated in Article 33 of the REACH Regulation by providing this information on the associated safety data sheet.
Further customer inquiries are thus unnecessary.
Brüggemann prepares the safety data sheets (MSDSs) in accordance with the requirements of the REACH Regulation (EC) 1907/2006 Annex II. The MSDSs are regularly checked, and updated if necessary.
BRÜGGEMANN applies the regulations concerning the safety data sheet in accordance with Art. 31 in conjunction with Annex II of the REACH Regulation
BRÜGGEMANN customers always receive a safety data sheet when they first purchase a product or if new information that may affect risk management measures or new information concerning hazards becomes available, if the product was purchased within the last 12 months.
BRÜGGEMANN will continue to exceed legal requirements in the future, and will provide a safety data sheet for all products, i.e., also for those products that do not contain any hazardous substances above the consideration limit.
The updated safety data sheets for substances or blends for which a Chemical Safety Assessment (CSA) must be carried out and a Chemical Safety Report (CSR) must be prepared also contain the information obtained in the course of the chemical safety assessment, i.e., the DNEL and PNEC values and the relevant exposure scenarios.
BRÜGGEMANN investigates the interactions of manufactured or imported substances on human beings and the environment.
For hazardous substances with an annual volume of 10 tons or more, a Chemical Safety Assessment (CSA) is carried out.
On the basis of this assessment, the Chemical Safety Report (CSR) is prepared, which contains all necessary risk management measures.
The user must strictly comply with these measures to ensure that the substance can be used safely.
Since 2010, BRÜGGEMANN has classified, labeled, and packaged substances in accordance with the CLP Regulation (EC) 1272/2008.
On the other hand, safety data sheets prepared by 31 May 2015 also still contain the classifications according to the Substances Directive 67/548/EEC in the MSDS.
This is necessary in order to comply with regulations that refer to the “old” classification. BRÜGGEMANN classifies, labels, and packages mixtures in accordance with the CLP Regulation in advance of transition deadline of 01 June 2015. There is a transitional regulation for labeling on product packaging until 2017. So until 1 June 2017 it’s possible for a product to still be labeled in accordance with Directive 1999/45/EC, while the corresponding GHS label is shown on the safety data sheet. In this case, the GHS label is then authoritative for industrial safety measures.