January 2010

REACH

REACH; the European Union regulation for the Registration, Evaluation, Authorisation and restriction of Chemicals entered into force in June 2007. REACH is an on-going compliance process which will have a significant impact to the business of all manufacturers, importers and downstream chemical users. All have specific obligations under the new legislation and Champion Technologies is well informed of such developments.

Pre-registration of Existing Substances

The REACH regulation allows for the pre-registration of existing substances to enable importers and manufacturers to benefit from transitional periods for full registration of substances. This is to ensure that there will be no disruption in the supply and marketing of these substances to Downstream Users (DUs) during the registration period. This preregistration period lasted for 6 months and expired on the 30th November 2008.

Champion Technologies successfully completed the pre-registration of the substances we manufacture and/or import within this time to ensure we can maintain the supply of products containing these substances to our European customers. We recognise that information on REACH status for our products is critical to our customer’s assessment of REACH impact and we are willing to share the REACH registration status of products with customers.

Helping you meet your obligations as a Downstream User

Ensuring full continuity of business relationships throughout implementation of REACH is of primary concern to Champion Technologies. One of the key obligations facing our customers as DUs is to ensure that their product use is adequately described and relayed to their suppliers, which will include Champion Technologies. The objective of this obligation is to categorise the “identified use” for each product in their supply chain. This will enable each supplier to prepare an exposure scenario, or if appropriate a use and exposure category, in the relevant chemical safety assessment pertaining to their customer’s identified use (REACH Art 37.2)

It is likely that the identified uses for the majority of chemicals used offshore will be very similar to their use by industry onshore. Champion Technologies as a formulator and end user ourselves have information on identified uses to pass on within the supply chain. You as our customer can also include your end uses in this process. Alternatively you can communicate your end uses directly to the European Chemicals Agency (ECHA). However, to aid the communication of uses for our customers, Champion Technologies have put together a matrix of our chemicals and our customers’ anticipated end uses. We have circulated this information to our customers and following their input have now communicated these end uses up our supply chain to the REACH registrants as the majority of our buy in chemicals will have a 2010 registration deadline.

It is expected that there will be substances that are used exclusively offshore, and some of these in relatively large quantities. So, in order to facilitate the development of appropriate exposure scenarios, an industry initiative involving the European Oilfield Speciality Chemicals Association (EOSCA) has proposed a standard approach to developing use and exposure scenarios to facilitate offshore chemical use to be included in the chemical safety assessments (CSA). As a member of EOSCA we have been working on development of the tool which will enable a Tier 0 and Tier 1 evaluation of offshore uses of substances. This tool has been developed by BMT Cordah on behalf of EOSCA and draws on existing risk assessment models. On the human health aspects it references the European Centre for Ecotoxicology and Toxicology of Chemicals’ (ECETOC) Targeted Risk Assessment (TRA), the HSE’s Estimation and Assessment of Substance Exposure (EASE), and other models specific to dermal or inhalation assessment. For the Environmental aspects it references the EU TGD, CHARM and Proteus. EGEST is freely available to download from

www.eosca.com/EGEST/Index.htm

If you require more information on this please contact our REACH implementation team at REACH.EU@champ-tech.com