ERAMET pays special attention to the handling of chemical substances to ensure a high level of protection for human health and the environment. As such, ERAMET deploys the resources needed to ensure enhanced knowledge of the properties of substances placed on the market and takes into account the various regulations in force, in particular the European REACH regulation. In accordance with the "no data, no market" principle, non-compliance of the procedures and deadlines imposed by REACH results in a ban on placing products manufactured, imported or used by industrial players on the market. The various actors of the value chain must therefore organize themselves collectively to ensure the application of the regulation, both on their own sites as well as those of their suppliers and customers, in particular through mechanisms for the exchange of information.
Registration of Chemicals Prior to Any Use
As part of the European REACH regulation which entered into force in 2007, a large number of chemical substances and products must be registered. This regulation which is a benchmark in terms of the management of chemical products, is designed to ensure better protection of employees' health, the population and the environment.
The registration dossier brings together all the existing scientific data about the substance in question: its composition, physico-chemical properties, the assessment of its impacts on the environment and health, its uses, etc. To compile it, ERAMET mainly uses information provided by the users of its products downstream, in particular:
- the duration and frequency of use;
- the level of emissions and exposure;
- the risk management measures in place etc.
These elements are then subject to a chemical safety assessment and the customers' uses are thereby covered when registering the dossier.
Joint Preparation of the REACH Registration Dossiers
Under the REACH regulation, the ERAMET group has carried out 55 registrations to date. Customers of the Group are invited to participate in preparing for registration by sending a brief general description of their uses. This information is taken into account in establishing scenarios of exposure for the dangerous substances or preparations in question. These scenarios are tailored to each of the uses and form the basis of the risk management measures. ERAMET's customers are also required to inform it about any new information regarding the use of the substance or preparation and the risk management measures deployed so that the registration can be updated.
Flow of Information Right Down the Chain
Placing dangerous preparations or substances on the market requires specific labeling as well as the development of a material safety data sheet (MSDS). This is a document providing users downstream with information about health and environmental hazards linked to the use of the product, as well as guidance on means of protection and what to do in an emergency.
Safety data sheets now incorporate the risk management measures resulting from the exposure scenarios.
In order to provide its customers with reliable and relevant information, the ERAMET group actively contributes to the development of scientific knowledge about metals through its participation in various professional and scientific organizations.
New Collaborative Methods
In parallel with the registration procedure, the industrial players are working to adopt a common approach to dealing with authorization and restriction procedures. When ECHA or a member state proposes the inclusion of a substance on the candidate list (or when it is felt that a substance will eventually be included in this list), the players concerned by this substance exchange relevant information on the procedure and on the coordination methods with a view to authorization or restriction. Generally, this initiative is launched by the producers of a substance (through professional associations) or by the main or most active producer. The ERAMET group participates in several exchange arrangements which meet this goal of transparency and efficiency.