Dr Knoell Consult Ltd is a member of the knoell group of companies, specialising in registration of industrial chemicals and agrochemicals. With an in-depth knowledge of the chemical industry in the UK, the team of scientific experts works in partnership with clients to achieve cost-effective solutions for regulatory compliance.
Case Study
The transitional arrangements for the implementation of the CLP regulation means that in general, the rules governing the classification, formulation and labelling of mixtures does not change until 1st June 2015. In the meantime however, the implementation of REACH means that formulators must not only be alert to ensure that the chemical substances in their supply-chain have been registered (or have an appropriate registration plan), but also be aware of the impact of the other aspects of REACH, especially the candidate list of substances of very high concern (SVHC).
Our client was a small company importing tailor-made formulations which were supplied to a niche industrial application. We were asked to help them understand their supply chain and produce a strategic plan for compliance with REACH. The first step was to obtain the composition of the products from the producer and from this to produce a list of substances and annual import volumes. The initial evaluation of the imported substances highlighted a low level of a substance which met the criteria to be a substance of very high concern (SVHC). REACH states that such substances with an import volume above 1 tonne/year should have been registered by 1st December 2010.
The import volume of the SVHC substance was well below the threshold for registration, but business growth had led to increased volumes and now the possibility of registering had to be considered.
In addition, the substance was added to the ECHA Candidate List of substances for authorisation. This placed a new obligation on our client to provide a safety data sheet (SDS) for the formulation (even though the level of the substance was below the threshold for classification).
Using the experience gained through working with the REACH regulations since 2007, we were able to advise our client on sourcing of the SVHC substance within Europe, thus removing the obligation on our client to register the substance. The expert team at Dr Knoell were also able to produce a SDS for the formulation to help our client comply with the current rules for substances on the candidates for authorisation list.
The regulatory process is a constantly changing landscape, and working with Dr Knoell Consult Ltd provides industry with an independent, expert partner on the road to regulatory success.
