Regulation Compliance

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Regulations and Compliance

Brady R.E.A.C.H. information


1. INTRODUCTION AND BRADY POLICY

As of June 2007, the European Regulation 1907/2006 concerning the Registration, Evaluation, Authorization and restriction of Chemicals (REACH) came into force.The objective of the legislation is to protect human health and the environment from the risks arising from the use of chemicals.
It has taken 7 years of discussion before this legislation was approved by the European Parliament and it will affect the manufacturing and import of substances placed on the European market, either on their own, in preparations or in articles, for the next 20 years.

Two of the main obligations under REACH are:
1- Registration of all substances (in all its forms) put on the EU market and
2- Communication on Substances of Very High Concern (SVHCs) present in articles put on the EU market.

1.1 REGISTRATION OBLIGATION
All substances in quantities of 1 tonne or more per year need to be registered. Depending on the volumes and the hazardousness of the substance this has to take place in 2010, 2013 or 2018 and can include (expensive) tests to assess the effect on human health and environment. Substances already on the EU market had to be pre-registered before 1/12/2008 in order to stay in the European market after this date. If pre-registration is missed, the substances have to be withdrawn from the EU market.

BRADY ACTIONS
During the past months, Brady has been investigating the different responsibilities of its different roles to play under the REACH legislation.
As an importer, we have reviewed all the quantities we import into the EU and as we did not import a tonne or more of any one substance, we have no registration obligations.
As a down stream user, Brady has been in close contact with its suppliers to get the required confirmation that they, or their sub-suppliers, will register the substances in scope.
Now that the pre-registration period has ended, Brady is happy to confirm that we do not expect any disruption in our supply chain due to the registration obligation of ourselves or our suppliers.

1.2. SUBSTANCES OF VERY HIGH CONCERN (SVHC)
The European Chemical Agency (ECHA) will, based on the test results, determine whether some substances have to be restricted or need to be authorized for certain applications. Today there are already 38 SVHCs identified on the candidate list, 15 in October 2008, 14 in January 2010, 1 in March 2010 and 8 in June 2010 (http://echa.europa.eu/chem_data/candidate_list_table_en.asp), but more will be added by ECHA; 3000 substances (!) are currently under review.

BRADY ACTIONS
At this stage, Brady needs to have full visibility on the presence of these 38 SVHCs in all products we sell on the European market. Under REACH it is an obligation to inform customers on the presence of a SVHCs >0,1% w/w in the products sold in Europe.
Later, as more SVHCs will be published, Brady has to broaden the knowledge on the presence of these new SVHCs in its products, and as soon as substance restrictions and authorizations are announced, Brady has to comply by potentially redesigning the products.
If there would be a product with SVHC present, Brady will inform its customers, including safe usage instructions.

2. BRADY ORGANISATION
During the last 9 months Brady has involved 13 people in preparation for this legislation. In Europe, a team of local REACH coordinators has been established for each site. These coordinators are in close contact with the suppliers to obtain the requested SVHC information and are organising the feedback on the customer requests.
For specific questions related to our products and REACH, please contact your local REACH coordinator (see list below) or your local customer service coordinator.

UK - john_suthons@bradycorp.com
Italy - Giorgio_Zanoletti@bradycorp.eu
Germany - Sabine_Lehmann-Klose@bradycorp.com
France - Francois_Baveye@bradycorp.com
Spain / Portugal - Francois_Baveye@bradycorp.com
Benelux - RoHS_Europe@bradycorp.com
Central Europe - andrea_panikova@bradycorp.com
Denemark / Sweden - magnus_wangelin@bradycorp.com
Norway - Asgeir_Seljen@bradycorp.com

3. FREQUENTLY ASKED QUESTIONS
See link http://echa.europa.eu/reach/faq_en.asp

4. EXTERNAL LINKS
More information about the legislation can be found on
http://echa.europa.eu/

5. Reach Training video
In this 10 minute video, the following topics are presented and discussed
Basics of the REACH legislation
- Substance Registration
- Substances of Very High Concern
Activities within Brady
Status of our Products
Customer Requests
Communication