REACH & GHS

The world of chemical regulatory compliance is becoming increasingly complicated as product sourcing and formulations grow more complex and organizations expand into new markets on a global scale. New initiatives such as REACH and GHS add to the challenge of keeping on top of compliance issues.

GHS (Globally Harmonized System for Classification and Labeling) is the UN system for harmonization of classification and labeling of chemicals. GHS is already implemented and required in Japan and New Zealand. Korea has implemented GHS and will be required as of June 30, 2008. The EU and Australia have drafted a GHS regulation. The implementation and requirement timelines for GHS and REACH are closely tied together in Europe.

REACH (Registration, Evaluation and Authorization of Chemicals) is a the new EU regulatory framework for managing chemical substances in Europe. REACH enters into force June 1, 2007 and some of the requirements will be registration of chemicals, authorization of use of certain chemicals and new and extended requirements to the information in the MSDS.

Companies with European production or distribution of chemical substances and companies that import into Europe are affected by REACH and should go through several steps in preparation:

• Establish an inventory of substances, which includes the identity (CAS number), tonnage and known EU classification


• Develop the ability to de-formulate any mixtures that are exported to the EU, by volume


• Determine their own REACH role for each substance, i.e. Manufacturer/Importer or Downstream User


• Check if any of the substances are likely to get on the candidate list, which would result in authorization requirements


• Update Material Safety Data Sheets by June 2007

Define Your REACH Role
Non-EU manufacturers should understand the registration obligations of any EU importers they work with and help them to not miss the pre-registration deadline. If registration is required, they should be prepared to support the registration.

EU Manufacturers/Importers should decide which substances to register and when. They should also consider substitution of most hazardous substances.

Downstream Users should inform suppliers of use and also consider substitution of most hazardous substances.

How 3E Can Help
3E products and services help companies with the preparation process and with on-going compliance thereafter.

Ariel EH&S Decision Support
Ariel chemical and regulatory data now includes relevant REACH legislation. The final REACH Regulation is available in Ariel WebInsight. Lists of chemicals will be added once they are published by the European Chemical Agency. Ariel WebInsight provides access to existing IUCLID substance dossiers.

3E Online®-MSDS Management
3E's industry-leading MSDS management system, 3E Online-MSDS: Expert Edition provides advanced compliance management capabilities, which should prove valuable for companies impacted by REACH regulations.

• Inventory Management - Obtaining and maintaining raw material MSDSs and the full composition of mixtures helps companies establish which category individual substances fall into: manufactured within the EU, imported into the EU or purchased from a supplier within the EU. Companies can also identify each substance's tonnage and current classification. A clear and accurate chemical inventory is the foundation for any hazardous substance management system.


• 3E-Ariel RegImpact - 3E Online-MSDS: Expert Edition includes the 3E-Ariel RegImpact module, which provides regulatory reporting and chemical and data analysis features such as ingredient and product properties modification and quantity/inventory tracking, such as the ability to identify the monomers from which the polymers are made, and track annual volumes of manufactured or imported substances and preparations, including composition (the substances contained in each preparation).

Ariel MSDS Authoring
3E can assist companies with obtaining the necessary overview of the REACH regulation as it stands today and how it relates to their chemicals and their supply chain. Ariel MSDS Authoring services assist manufacturers, users and distributors in fulfilling their obligations to downstream customers and employees. As companies consider the impact of REACH on their MSDSs for updates and/or new MSDSs, Ariel MSDS authoring services are a natural choice.

3E's own multi-lingual staff create, analyze and manage globally compliant MSDSs, product label content and hazardous materials transportation documents covering regulatory and language requirements for dozens of countries, including EU members. 3E can support the additional information requirements for the Extended Safety Data Sheets as required by REACH.

Professional Services
Still don't know where to start? 3E can help identify specific responsibilities and establish an action plan for your company to execute.

Each of 3E's services comes with a variety of options and enhancement modules that can be integrated into the leading EH&S systems, custom systems, or configured based on a customer's EH&S information management needs. Contact us for more information today