SHE Department: +86.21.3920.1618
SHEQ Department: +31. 297.544.568
SHE Department: +61.2.8336.8532
SHE Department: 610.832.8665
SHE Department: Tel: +55.21.3305.1800
SHE Department: Tel: +64.9.579.2029
To this end:
- We are committed to the belief that all incidents are preventable. We will pursue this through appropriate risk identification, management and corrective actions to establish Quaker as a premier place to work.
- We will seek to integrate safety, health, environmental, & security considerations in all planning for equipment, facilities, products and processes. We will seek appropriate design considerations to protect the health and safety of our associates and the communities in which we operate.
- We will seek to promote pollution prevention through improved process efficiencies, source reduction, reuse and recycling.
- We will employ the SHE&S Management System to drive continual improvement in all aspects affecting Safety, Health, Environmental, & Security.
- We will use our best efforts to identify SHE&S issues and take appropriate actions, which may precede the enactment of applicable laws or regulations.
- We will comply with all applicable SHE&S laws, regulations, permits, and other requirements to which we subscribe. We will employ more restrictive internal standards where appropriate to comply with the above policy.
We expect all Quaker associates to understand, promote, and assist in the implementation of this policy.
Michael F. Barry
Chief Executive Officer and President
January 29, 2016
Registration, Evaluation and Authorization of Chemicals
REACH (Regulation (EC) No.1907/2006) is the European Union’s new legislation to manage chemicals. It came into force on June 1, 2007 and as a regulation, took immediate effect in all EU Member States.
REACH Department Contact
The Chemicals Policy in the European Union
In the European Union (EU), chemical manufacturing is the third-largest industry, including 31,000 companies employing 1.9 million people.1 Chemicals are important to the EU economy.
Use of these substances may pose risks. Recorded incidents of allergies, some cancers and reproductive disorders are on the rise in Europe, and chemicals may be a cause. In addition, studies show that some animals (frogs, birds, fish) suffer infertility and gender changes, related to certain chemicals affecting hormones.2
More than 100,000 chemicals were on the EU market in 1981 – of which 30,000 are manufactured on a regular basis – and we know not so much about them. (Till May 2015 approx. 8400 registration reports of unique substances have been submitted to the ECHA (European Chemical Agency) in Helsinki).
To lessen risk and improve transparency, the European Commission has developed a regulatory system called REACH. The intent is to better protect human health and the environment, while enhancing competition by fostering innovation and ensuring high safety standards for chemicals.
REACH requires companies to take responsibility for the chemicals which they manufacture, import or supply in the EU. While a major part of the responsibility is with the original EU manufacturer of the chemical or the EU-based company that imports it into the EU, all organizations which mix chemicals into other products and users of those products also have obligations under REACH. They must submit information on properties, uses and safe handling. Working together and sharing data among companies is encouraged, for the betterment of the industry. Communication between suppliers and users of chemicals – the supply chain – is an essential part of REACH.
Pre-registration – The first stage of REACH
All substances currently in use in the EU must have been pre-registered by each manufacturer and importer before December 1, 2008. FAILURE to PREREGISTER means that you are no longer allowed to manufacture, import or supply in the EU. However it is possible to late pre-register substances which are manufactured and imported but only when the volumes are low (<100 ton/year).
Registrations – The second stage of REACH
All substances manufactured in or imported into the EU at more than one ton/year/manufacturer or importer have to be registered. This will involve the submission of a dossier of data to the ECHA in Helsinki. This dossier has to include data on the hazardous properties of the substance, its uses and, in most cases, a risk assessment (Chemical Safety Report) covering each different type of use. The actual data in the dossier and when the registration has to be submitted will depend on the hazards of the substance and the amount manufactured or imported by each company.
The first phase substances to require registration will be those classified under EU law as Category 1 and 2 carcinogens, mutagens and reprotoxins (CMR); those classified as R50/53, (Very toxic to aquatic organisms, may cause long term adverse effects in the aquatic environment) and manufactured or imported at >100 tons/year; and substances manufactured or imported at >1000 tons/year per manufacturer. These substances must have been registered by December 1, 2010.
The second phase substances to require registration will be those manufactured or imported at >100 tons/year – <1000 tons/year per manufacturer. These substances have been registered by June 1, 2013. The third and last phase substances to require registration will be those manufactured or imported at >1ton/year – <100 tons/year per manufacturer. These substances must be registered by June 1, 2018.
Quaker submitted dossiers to ECHA in 2010 and in 2013 successfully and will submit dossiers in the coming years.
Evaluation – The third stage of REACH
There are two stages to an evaluation:
- Dossier Evaluation – The registration dossier will be checked for completeness and it will be decided if further information is required to complete the risk assessments.
- Substance Evaluation – The hazardous properties of a substance and the way that it is used will be subject to a detailed evaluation by the competent authorities in the EU member states. If there are no concerns, use of the substance will be allowed to continue. If there are concerns, additional information may be requested or controls on the use of the substance may be proposed. Substances will be prioritized for this evaluation based on their level of risk to human and environment. At this moment Quaker is awaiting the evaluation (dossier and substance) by ECHA. Quaker has re-submitted on request of ECHA some dossiers and in another case Quaker is in discussion with ECHA about the substance identity.
Authorization & Restrictions
This will be applied to the most hazardous substances such as Category 1 and 2 CMR substances, identified as PBT or vPvB and endocrine disruptors. These substances (a list created by ECHA and marked as Substances of Very High Concern) will only be allowed to be used if specific permission is granted by the European Commission. Such permission will be time-limited on a case-by-case basis.
If use of a substance is shown to be unacceptable for human health or environmental reasons, restrictions or even prohibitions on use may be introduced – REACH restrictions will replace the current restrictions under the existing Marketing and Use Directive, 76/769/EEC and its amendments, as of June 1, 2009. All existing restrictions have been transferred into REACH.
Raw material manufacturers are responsible for registration, so Quaker’s main task is to coordinate with suppliers on affected materials. We invest important resources to put into conformity our raw materials and range of products. Quaker may decrease suppliers or find safer alternatives. If some substances are discontinued, we will have to re-formulate products.
While this is currently an EU legislation, other countries like South Korea and Turkey are in the process to activate REACH like regulations, it will be a matter of time other countries will follow and span the globe. REACH already impacts Quaker beyond Europe. Epmar, AC Products, Summit Lubricants and G.W. Smith and Sons, Inc., our subsidiaries outside Europe, export products to Europe and therefore must comply with REACH.
We know EU-REACH has and will affect industry prices to a certain extent, and expect supplier costs to influence Quaker costs. However, the full implications will not be apparent until after the regulations (2018) are implemented.
| Fact 1: We need chemicals and a strong industry|
Fact 2: Chemicals can pose risks, but information is sketchy
Fact 3: REACH regulation will provide an increase level of protection mankind and environment
ECHA: European Chemicals Agency
REACH: Registration, Evaluation and Authorization of Chemicals
CMR: Carcinogens, Mutagens and Reprotoxins
PBT: Persistent, Bioaccumulative and Toxic
vPvB: very Persistent and very Bioaccumulative
SVHC: Substance of Very High Concern
1 “Fact and figures – The European chemical industry in a worldwide perspective,” January 2005, European Chemical Industry Council (www.cefic.org/factsandfigures/).
2, 3 “Environment Fact Sheet: REACH,” 2006, European Commission.
GHS requires the use of a 16 section Safety Data Sheet with a specific
order of the sections. Sections include:
- Hazard identification
- Composition/information on ingredients
- First aid measures
- Fire-fighting measures
- Accidental release measures
- Handling and storage
- Exposure controls/personal protection
- Physical and chemical properties
- Stability and reactivity
- Toxicological information
- Ecological information
- Disposal considerations
- Transportation information
- Regulatory information
- Other Information
Elements within each section are also specified. The SDS must inform its audience of the hazards of the material and provide information on the safe storage, handling and disposal of the substance or mixture. Material should be presented in a consistent and complete form with the workplace audience as its basis. Others may use all or part of the SDS including employers, health and safety personnel, emergency response personnel, medical personnel and government entities.
- Signal word
- Hazard statements
- Precautionary statements and pictograms
- Product identifier
- Supplier identification
Examples of pictograms include:
In addition, there is mandatory wording of the hazard and precautionary statements. GHS recommends the format of a label but does not require a standard format. Companies can format their labels as long as they include the minimum data elements. They are free to add additional items on the label as long as it does not conflict with the required elements.
GHS is the Globally Harmonized System for Classification and Labeling of Chemicals. GHS was developed by an international group of experts with the support of the United Nations for standardizing and harmonizing the classification and labeling of chemicals around the world. OSHA has adopted portions of the GHS which is called the Hazard Communication Standard (HazCom 2012). These are not laws or regulations, but a set of guidelines for ensuring the safe handling, production, transport, use, and disposal of hazardous materials.
Quaker is fully committed to complying with the requirements of HazCom 2012 and is working extensively to ensure compliance by OSHA’s deadline of June 1, 2015. As a chemical manufacturer, we are required to assess the hazards of every industrial product and prepare labels and SDSs in the new format to communicate the hazard information to users and customers.
Quaker is dedicated to helping our customers and distributors understand the changes under way and has allotted substantial time and resources to ensure a smooth transition. Quaker will continue to support the transition through compliance by June 1st, 2015, access to GHS formatted SDSs, proper classification of products, ongoing training for new employees as well as refresher courses available on our intranet. In addition, Quaker will not display HMIS labelling on TD or SDS sheets in order to avoid confusion with the new system. Please keep in mind our formulas have not changed even though some of the hazard warnings may change.
It is important to know that Quaker has not altered product formulations as a result of GHS. Under GHS, the classification system has changed resulting in new hazard classifications and warnings. The Hazard Communication Standard will enhance the protection of human health and the environment, provide a recognized framework for those countries without an existing system, and reduce the need for testing and evaluation of chemicals.
You can get more information on Quaker’s GHS implementation from the brochure here. If you have further questions regarding Quaker’s implementation of GHS, please feel free to contact your Quaker Representative or send questions to firstname.lastname@example.org.
The information provided within this document is for reference purposes only and reflects Quaker’s understanding and ongoing actions to comply with GHS and HazCom 2012. We encourage customers and distributors to consult their own regulatory advisors and legal consultants regarding specific actions within their company. For more information, please visit OSHA’s website: www.osha.gov/dsg/hazcom/