Frequently Asked Questions

REACH regulation

When should I act?

Depending on the role (s) your company plays, you will have to deal with different REACH requirements. Different requirements apply to users and to producers.

Does REACH apply to me, as a user?

Yes, if you use chemical base materials in your company it is almost certain that even as a user you will have to deal with REACH. Users of substances (irrespective of whether they are in preparations or objects or not) will have to, among other things, provide their suppliers with information on the use of those substances, as preparation for or adjustment of a registration.

Who is my “supplier” within the context of REACH?

The company that you buy the chemical substance/preparations(s) from. In the case of Interflon, for instance, that would be the local Interflon sales organisation, not the manufacturer.

Will the substance I use (or make) fall under REACH?

Please read article 2 and appendices IV and V of the REACH regulation to find out whether or not your substance has been exempted from REACH.

What information should I have to provide?

Information about the use and exposure scenarios (for environmental and health risks) and operational conditions under which the substance is used. Your suppliers will use this information, for instance in drawing up the exposure scenario.

What is “pre-registration”?

Substances that are submitted to the European Chemicals Agency (ECHA) between 1 June 2008 and 1 December 2008, may still be manufactured and used in the period 2010-2018, if they pose no immediate danger to the environment and public health. In the meantime, all base materials that Interflon B.V. uses in producing its lubricants and cleaners have been pre-registered with ECHA.

What will happen if I do not do anything now?

If you do nothing, you will no longer be allowed to use substances/preparations for which your use has not been registered. In the interests of your continued operations, it is, therefore, very important that you ask your supplier to register your use if this deviates from the information in the material safety data sheet (MSDS).

Which Dutch institutions are responsible for the enforcement?

The three inspectorates, the Labour Inspectorate (Arbeidsinspectie), Food and Consumer Product Safety Authority (Voedsel en Waren Autoriteit) and the Inspectorate of the Ministry of Housing, Spatial Planning and the Environment (VROM), will conduct targeted inspections of REACH compliance by companies. Their efforts in this matter will be boosted by the European Chemicals Agency (ECHA).

Important points of attention for 2008 are the inspection of the use of material safety data sheets (MSDS) and the passing on of information concerning substances and preparations in the chain, and the provision and use of MSDSs by end users.

What sanctions do I face if I (un)consciously fail to comply?

Non-compliance with REACH regulations has been a punishable offence since 1 June 2007 as an economic offence (criminal law). In the event of intentional failure to comply or deception, there is talk of a crime. Sanctions are imposed on individual offenders, but also on managers and companies.

What do I do in case of calamity?

As fast availability if of vital importance in case of calamity, Interflon submitted the safety information of its products to the national poison centres. These centres provide information about health effects and treatment of acute poisonings to medical workers and public bodies 24 hours a day, 7 days a week. In case of calamity, please contact your national poison centre immediately, in England.

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