Long time has passed since we started the REACH project. It was back in 2002 when we first heard that the European Commission is preparing a new legislation which will replace over 40 different laws. Cefic, the European Chemicals Industry Council, opposed the regulation fiercely, but in vain. The Commission with the European Parliament won finally and the regulation came into force in 2007 in all EU countries. The REACH regulation increased substantially the workload of the industry. Now it is the industry which is responsible for studying hazards of their products and finding safe ways to use them. Before, this was the task for authorities.
The REACH regulation is really complicated and only a few companies, normally the largest multinationals, have competence to apply it by themselves. But the industry made a clever move and formed several consortia, where resources could be pooled; outside experts hired and cost divided. For NEXBASE® 3000 series base oils (VHVI) we found CONCAWE (European Oil Company Organisation for Environment, Health and Safety) as an ideal consortium. CONCAWE had been active quite from the beginning and succeeded to convince the Commission that one common dossier will apply for all similar substances. Dossier is the document which is delivered electronically to the European Chemicals Agency. It includes results of the chemical, physical, human and environmental studies.
Finally, our NEXBASE® base oils were registered in autumn 2010. We have often wondered whether there are any benefits from the REACH. Or is it just a costly exercise? Future will show it, but never before have we known so much about e.g. health and environmental properties of our base oils and other base oils on the market today. Luckily, it turned out that most of NEXBASE® base oils will not be classified as hazardous substances and some base oils have only aspiration hazard, which is not a severe classification. This proves nicely the purity of our top-tier NEXBASE® base oils. Having the deep knowledge of our products is another advantage that we have among other high quality products and services that we offer to our customers.
The other dimension is our customers, downstream users as we call them in REACH jargon. By the way, REACH jargon or language has become popular among REACH professionals. We speak about competent authorities, CMRs, CSAs, DNELs, PNECs, exposure scenarios, PROCs, IUCLID and LRs, just to name some. Can you open them up? Most people don’t; and do not actually need to. It is our task to explain the outcome in common language. But back to customers. Along the length of the REACH journey we have had very active and productive communication line with base oils customers for several years. We would like to thank our NEXBASE® sales people for providing a wide range of information and data e.g. uses of the base stocks. NEXBASE® related uses are now included in registration dossiers and Safety Data Sheets of the products.
The main hurdle may be over, but when new products and uses will appear, dossiers have to be updated or new ones to be created. Updated safety data sheets will be delivered to our customers in near future. REACH regulation is valid for the European Union, but several other countries have adapted or are developing similar legislations. Data collected for REACH could be used in these countries. We also create a practical Product Stewardship handbook for our sales people when they start exporting our base oils to new market areas or countries e.g. in the Middle East.