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Meeting the Requirements of REACH

Customer-driven excellence is a strategic concept within MTI that demands constant awareness of changing and emerging customer and market requirements. At MTI, it is not good enough to simply meet product requirements.  We must also understand the features of our products and services that contribute value to our customer's processes. We place great importance on listening to our customers. One of the emerging issues for our customers located in or supplying products to Europe is a new chemical regulation known as REACH.

What is REACH?

REACH is an acronym for Registration, Evaluation and Authorization of CHemicals. This is a new law that became effective throughout the European Union (EU) on June 1, 2007. REACH applies to all companies that manufacture or import chemicals or articles containing chemicals into the EU.  REACH requires these companies to identify the environmental, health and safety risks of each chemical as well as specify proper safety measures to protect those who use these chemicals in downstream applications. This information will be made public through a registration process.  A new European Chemical Agency (ECHA) will manage the registration data. 

REACH will be implemented in a phased approach.  Importers and manufacturers of existing chemicals have the option of pre-registering their substances between 1 June and 30 November, 2008.  Companies that pre-register will have 3.5 to 10 years to submit the full registration.  Companies that do not pre-register must complete the registration process before the end of 2009.  If a chemical is not pre-registered or registered within the specified timeframe, it may not be manufactured in or imported into the EU. 

The regulations implementing REACH contain exemptions from registration for specific substances, including minerals which occur in nature, provided that these minerals are not chemically modified[1].  REACH also does not require registration of mixtures, although it the individual components of the mixture must be registered.

How is MTI preparing for REACH?

MTI has developed a REACH Implementation Team to evaluate the impact of this new law for all of our operations and our customers.  The Team includes operations, sales, research, supply-chain, environmental, health & safety and legal experts from all of our businesses.   Based on the information available at this time, the Team has concluded that: 

  • The majority of Minteq's refractory products are classified as mixtures (preparations) and do not require registration.  Minteq will ensure that the suppliers of the individual components are meeting their registration requirements.  Minteq will also update our Material Safety Data Sheets as new information is obtained from our suppliers.
     
  • Minteq produces or imports some materials, such as calcium metal that must be registered before December, 2010.  Minteq will ensure that these materials are pre-registered in 2008.   Minteq will then join with other manufacturers and importers to develop appropriate registration applications.
     
  • The limestone and talc products produced by Specialty Minerals Inc. (SMI) are considered "minerals which occur in nature, if they are not chemically modified" and therefore are exempt from registration (REACH Article 7 of Annex V).
     
  • At this time, precipitated calcium carbonate (PCC) products are not specifically exempted from the registration requirements of REACH.  However, SMI is cooperating with the Calcium Carbonate Association of Europe (CCA) in requesting an exemption under Annex IV of REACH from registration for PCC.  The basis of the application is the fact that PCC and naturally-occurring limestone are chemically identical materials.  As mentioned above, limestone is exempted from registration according to Annex IV where it is clearly described as consisting “primarily of calcium carbonate.” Calcium carbonate fully corresponds to the criteria for the inclusion of substances into Annex IV: sufficient information is known about the substance and it is considered to cause minimum risk because of its intrinsic properties. CCA is requesting a specific exemption for PCC under Annex IV based on the same criteria as used for limestone.  SMI is closely monitoring the progress of this request and is prepared to pre-register PCC after June, 2008 if the exemption is not granted.
     
  • Coated mineral products, including coated PCC, are classified as mixtures (preparations) and do not require registration.  SMI will ensure that the suppliers of the jndividual components meet their registration requirements.  SMI will update our Material Safety Data Sheets as new information is obtained from our suppliers.
     
Who can we contact for more information?

For further information about MTI's REACH Implementation plans or for information about a specific material, please contact us.

 
Learn more: 

REACH 

European Chemical Agency (ECHA) 

ReachCentrum

 


[1] Annex V, Section 7; page 305 of Regulation (EC) No 1907/2006 of the European Parliament and of the Council of 18 December 2006