REACH Regulation

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.

Regis­tra­tion

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.

SVHC: Substances of Very High Concern

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.

Safety Data Sheets

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

  • for dangerous substances or mixtures
  • for PBT and vPvB substances and for
  • blends containing SVHC substances in concen­tra­tions >0.1% by mass.

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.

Chem­ical Safety Report

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.

CLP Regu­la­tion

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.

 

Contacts

Dr. Isabella Hebeiss

Regulatory Affairs Manager

Tel.: +49 71 31 15 75-400

Fax: +49 71 31 15 75-25 400

ehs (at) brueggemann.com