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Gordon Hartley
Member - 2 posts
Glenair is what I would term a downstream user and under REACH the regs state that we have a duty to use materials under REACH safely.
Surely managing hazards and risks for anything classed as hazardous comes under CHIP which links up nicely with COSHH.
So where does COSHH and REACH begin to cross paths?
To me, as a user not a producer COSHH is more appropriate.
Any comments most welcome and thank you.
Gordon Hartley
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Dave Gill
Member - 8 posts
Gordon,
Also as a user not producer, my only comment is that I agree.
It seems to me that if we're already doing the whole COSHH thing (control, assessments etc...) then we are compliant with REACH.
Or am I missing something?
Dave
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Gordon Hartley
Member - 2 posts
In an ealier posting I said that Glenair was a user of products which can be bought off the shelf e.g. adhesives, potting medium, metals, coolants etc. We are constantly being bombarded with requests to list the chemical breakdown of end products we supply and advise customers what have we done to pre register their use to ensure their continued supply. The spreadsheets are becoming unbelievable/threatening and seem so pointless. How are others combatting what appears to be a silly excercise? REACH is surely about the Chemical Industry ( through the regulator) to produce safer and more environmentally products from which producers of down stream products can use, then people like ourselves are under COSHH applying due diligence in the safe hqandling and disposal should this be the case. Comments anyone?
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