This profile provides links to the Registration, Evaluation and Authorisation of Chemicals (REACH) Regulation process within MOD, together with an exemption application and the chemical reporting process.
REACH Regulation (EC) No 1907/2006, requires all chemical substances, new and existing, that are manufactured or imported into the European Union in a quantity of ≥1 tonne per year to undergo registration, with a gradual introduction of the obligations through to 2018. The UK REACH Enforcement Regulations 2008 (SI 2008/2852) came into force in Dec 2008. Further general information on REACH is available at the HSE web site (http://www.hse.gov.uk/reach/index.htm).
The aim of REACH is to improve the assessment and control of chemical substances and their impacts on human health and the environment:
Providing a high level of protection of human health and the environment from the use of chemicals
Making the people who place chemicals on the market (manufacturers and importers) responsible for understanding and managing the risks associated with their use.)
Allowing the free movement of substances on the EU market.
Enhance innovation in and the competitiveness of the EU chemicals industry.
Promoting the use of alternative methods for the assessment of the hazardous properties of substances e.g. quantitative structure-activity relationships (QSAR) and read across.
Further general information on REACH is available at the HSE web site (http://www.hse.gov.uk/reach/index.htm) or ECHA website http://echa.europa.eu/reach_en.asp.
Although it is the legal responsibility of all Defence Industry Partners to carry out registration of their substances under REACH, there is also the provision to enact a Defence Exemption from the requirement to submit MOD specific information to the European Chemicals Agency (ECHA) in the interests of Defence. It should be noted, however, that the MOD policy on exemptions requires that an equivalent REACH process be carried out internally, that meets the requirements of the legislation. Project Teams or Defence Industry Partners are urged to contact their suppliers to ensure that they are aware of REACH and have implemented plans to register of all the products they provide to your company. This will highlight where alternative suppliers, or products, need to be sourced after the REACH registration deadlines.
The MOD REACH Exemption Process
The document (MOD REACH Process document provides further information on MOD guidance and processes for REACH implementation and guides the user through the internal and external processes required to comply with REACH requirements and ensures that Defence Industry Partners, manufactures and suppliers are aware of the processes required to enact a REACH Exemption for Defence.
All applications for Defence Exemptions should be submitted though the partner Project Team (PT). Applications submitted through procurement teams will be scrutinised by an internal DE&S committee. The term Project Team (PT), used in all MOD REACH documents, equates equally to all individuals, teams, business units and sections that procure substances, preparations and articles within the MOD.
Where the requirement for a defence exemption, outside of the MOD PT customer base is identified, UK based defence industries should contact DESSESEP-reach to discuss their requirements.
Chemical Assessment and Reporting Process in the MOD - CAR (MOD)
The above link (Chemical Assessment and Reporting Process in the MOD) describes the requirement for, and guidance on, the chemical assessment process tailored for military use. It is an integral part of the MOD REACH Exemption process which provides a stepwise guide to gathering all the relevant information needed on a chemical substance to compile a MoD equivalent REACH Technical Dossier (TD) and/or compliant Safety Data Sheet (SDS). The assessment may identify the need to conduct a Chemical Safety Assessment (CSA) and document the results in the form of a Chemical Safety Report (CSR) which is outside the scope of this document.
SSD&C, HSE and DEFRA have supported CAR (MOD) and agreed that it meets the aim to provide an MOD process that mirrors the requirements of the legislation. The CAR (MOD) should be read by all MoD Project Teams (PT) and Defence Industry Partners (DIP) who are applying for or have been granted a REACH Defence Exemption in accordance with the MOD REACH Exemption Process. The CAR (MOD) is only for the guidance of Project Teams and Defence Industry Partners to enable chemical assessment of substances which are subject to REACH Defence Exemption. It is required that the applicants who have a MOD REACH Exemption, as a minimum, completes the CAR (MOD) unless the assessment identifiers a higher requirement (eg CSA). Any queries or comment on content or applicability should be addressed to DESSESP-reach.