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Ready for REACH
This information has been set-up to help you understand REACH and how Shell Marine Products is preparing to be REACH compliant.
What is REACH?
REACH is a new European Union (EU) regulation which stands for the Registration, Evaluation, Authorisation and Restriction of Chemicals, including petroleum substances and additives used in our fuel and lubricant products.
It came into force on 1 June 2007. By 30 November 2010, all substances manufactured or imported in quantities of over 1000 tonnes per year must be registered with the European Chemicals Agency (ECHA).
It is relevant to chemicals that we manufacture, buy (including imports) and place on the market in the EU. This includes all substances used in our fuels and lubricants products.
What are the objectives of REACH?
REACH is a European Union (EU) regulation which came into force in June 2007. REACH stands for the Registration, Evaluation, Authorisation and restriction of Chemicals. The objectives of REACH are as follows:
- REACH stresses the need to improve “the protection of human health and the environment from the risks that can be posed by chemicals” through the promotion of alternative test methods and free circulation of substance information on the market.
- REACH provides a single framework to regulate information about chemical substances in the European market. It makes the industry responsible for assessing and managing the risks posed by chemicals and providing appropriate safety information to users.
- REACH is one of a number of globally emerging regulatory changes which focus on increased product regulatory control.
Registration of product uses
Registration of Shell products under REACH will include the registration of specific product uses. Users of our products are responsible for reviewing the product-specific use information and deciding whether it describes the way in which they use the products. If, however, the products are being used in a way that is not described, users are invited to provide their feedback so that we can consider supporting the non-described usage.
Users can refer to the Material Safety Data Sheet for the product-specific use information. It is a REACH requirement that MSDS documents must be delivered before or at first product delivery to the users.
For substances used in our fuel and lubricant products, we have to demonstrate that a registered use is safe. This is done by carrying out a risk assessment that compares the estimated exposure for each use against a level that may be considered safe for health and/or the environment. If safe use cannot be demonstrated, then the registration of a specific use cannot be supported and advice must be given against this use.
The information describing the nature of exposure and the recommended risk management measures for the various identified uses will be documented in an Exposure Scenario and communicated to customers through an extended Safety Data Sheet.
How to review and respond to information on uses?
Our customers have an important part to play in helping to ensure we have a full picture of the uses of our products. This not only ensures that uses are correctly submitted as part of our registrations but that the exposure scenarios take known uses into account and provide the appropriate risk management measures.
So, what should customers do to support this process?
- Become familiar with the basics of how use information is documented. This is explained in the ECHA Use Descriptor System.
Go to the product use lists. Review the titles and scope covered by the listed Exposure Scenarios. Consider whether this reflects your uses of that substance - and beyond, down into the supply chain. If you recognize your operation here, you can expect that your uses have been addressed.
- If necessary, share all of this use information further into the supply chain (the manufacturer or importer’s responsibility stops at sharing information with their immediate customers).
- If, on completing your review, you think you use the product in a way that is not covered in a use descriptor, we welcome your feedback.
Please provide as much information as you can on your use of the product, but do NOT provide confidential information on the commercial application of the product or any other commercially sensitive information.
What impact REACH will have on Marine product portfolio?
As you are aware, Shell is in the process of re-launching its leading ranges of speciality lubricants to provide a simplified, yet comprehensive range to meet the needs of our customers and to take account of REACH legislation.
The impacted products are electrical oils, refrigeration oils and heat transfer oils under the following brand names: Shell Diala, Shell Clavus and Shell Thermia
This change will impact our products in one of three ways:
- No change will be made to the product but it will be given a new name.
- The current product will be updated and will continue to meet the same specifications and claim the same approvals; it will also be given a new name
- The current product will be discontinued in which case we will offer assistance in selecting an alternative.
Shell is currently undertaking an extensive OEM re-approval programme to formally transfer any existing OEM approvals and claims to any updated or rebranded products and to gain new approvals where they are required.
Shell plans to launch the rationalised portfolio in most of Europe in December 2010.
Please contact your Shell representative should you require more details.