OIP Sensor Systems in Oudenaarde wanted to perform another compliance check with regard to REACH. The company contacted the extensive Agoria network because they did not have the required expertise in-house. The company found its way through the complex and dynamic legislation using the REACH compliance tool.
REACH provides various challenges for companies, not just for producers but also for users of chemical substances. Complying with this EU regulation is not a one-off activity. This is because often hazardous substances are selected that not only require a far-reaching communication obligation but can, in various phases, lead to a system in which these substances may only be used after requesting and receiving the proper authorisation.
The acronym REACH stands for Registration, Evaluation, Authorisation and Restriction of Chemicals. It is an EU regulation that addresses the production, import, sale and use of chemical substances. The regulation applies to all companies that work with these chemical substances. The REACH regulation is complex but it is also dynamic. Substances of very high concern are added to the Candidate List for Authorisation twice a year. This is the first step to a potential system in which these substances may only be used as of a specific date if and when the proper authorisation has been issued. This first step already entails specific obligations, such as the communication or notification obligation for substances of very high concern used in objects. REACH also prescribes specific obligations regarding safety data sheets.
OIP Sensor Systems in Oudenaarde was established nearly a century ago. The company manufactured Precision Optics and Instruments (Optique et Instruments de Précision (OIP) in French). The company manufactured optomechanical instruments, such as microscopes, lenses, photographic cameras and developed further to manufacture high-tech defence equipment (night-vision devices, thermographical equipment, etc.) and space flight equipment (spectrometers, high-resolution cameras, etc.). The company's reputation as a reliable and high-quality supplier have led to ever larger and increasingly more complex projects.
OIP Sensor Systems decided to perform an additional REACH compliance check and contacted Agoria for advice. The REACH compliance tool guided OIP Sensor Systems through this substantial regulation and identified which actions were to be taken within the short term. Then an Agoria expert visited the company to clarify which steps had to be prioritised.
The internal prevention consultant drew up a risk analysis that tracked the use of substances of very high concern based on the latest safety data sheet updates and the European Chemicals Agency (ECHA) website. The use of chemical agents that contain SVHCs (substances of very high concern) is limited or isolated. The responsible party also draws up a flow chart to be able to map REACH compliance internally and to indicate the responsibilities to the departments concerned within this chain.
The communication and notification obligation for SVHCs in objects was once again checked for each part of the various products marketed by OIP. OIP checks the ECHA website regularly to stay up to date regarding substances that are added to the Candidate List for Authorisation or the Authorisation List. The main challenge for OIP Sensor Systems during this check was to raise awareness within other company departments.
Do you need help to ensure REACH compliance? Contact Agoria. Agoria has developed an update of the REACH compliance tool. The questionnaires have been updated and a few new questionnaires regarding authorisation have been drawn up to help Agoria members navigate through the complex REACH legislation.