REACH Regulation Compliance Case Study
The REACH regulations are concerned with the use of SVHCs (Substance of Very High Concern). The use of these substances is heavily controlled, requiring manufacturers to document the instances where these substances are used throughout the production of their product. More information on REACH and its impacts can be found here.
Our client is a leading blue-chip company heavily involved in the defence industry. Their primary products are in frequent use by the Royal Navy and Royal Air Force.
The client was aware that their processes were not compliant with the REACH regulations which are having an increasingly significant impact on many of the industries they’re involved in. The client did not have the expertise in-house to understand and amend their processes to bring them in line with the REACH regulations.
The client contacted CMCA(UK) to assist them with their efforts to become compliant.
The first stream of work that CMCA(UK) carried out was to understand which processes the client carried out that made use of an SVHC. Many SVHCs have uses in cleaning or plating and as such were previously widely used in industry. CMCA(UK)’s team of REACH experts went through in great detail all of the clients manufacturing processes to understand where SVHCs were in use. Having identified which processes were still utilising SVHCs, CMCA(UK)’s experts worked to define whether these processes left any residue behind on the final product, if more than 0.1%wt/wt of any SVHCon the REACH Candidate or Authorisation list was left on the final component it would need to be declared to the end user as part of the article 33 declaration.
The second stream of work was concerned with the components in use by the client in their finished products. Many of the components were bought in from external suppliers, this required CMCA(UK) to request information from the suppliers on their manufacturing process and the levels of SVHC present in their component supplied to CMCA(UK)’s client. Additionally the client manufactures in-house many of the components, this required a similar level of work in addition to the investigations carried out in the first stream of work, to understand exactly what substances were being used in the manufacturing process, whether as a component in the finished article or as part of the manufacturing process (plating or cleaning for example).
All of this information was then collated into a series of reports, which allowed the client to identify exactly where SVHCs were in use in their processes as well as where SVHCs appeared in their finished articles. This allowed the client to then make conscious changes to become compliant with the REACH regulations and avoid the punitive measures associated with non-compliance.
By engaging with CMCA(UK) the client was able to gain visibility of where in their processes they were exposed to REACH regulations and where they were non-compliant. This allowed them to implement changes to ensure their compliance going forward and to guarantee the on-going sustainability of their manufacturing processes without the use of SVHCs.
Why Choose CMCA(UK)?
Clients choose CMCA(UK) for many reasons, the most compelling of which are:
- We are a company that specialises in Obsolescence Management, Procurement and Long Term Storage solutions. It is our business to provide cost-effective, knowledgeable advice to our clients: after all, our excellent reputation depends on it.
- When it comes to Obsolescence Management, we pride ourselves on being innovative and progressive in our quest to develop practical, bespoke solutions.
- The client has access to market-leading strategic and tactical Obsolescence Management advice. This allows their In-Service Support team to focus its attention on the plethora of other engineering challenges, safe in the knowledge that obsolescence is being managed by the experts.