How REACH affects Morgan Thermal Ceramics
The Thermal Ceramics business of Morgan Advanced Materials has assessed its full product range and determined that a large portion of the products that we manufacture meet the definition of either articles or preparations for REACH. There is no need to carry out a REACH registration for either of these product categories as they fall outside the scope of the regulation if they are manufactured in the EU.
For those substances that we do manufacture or import we will be following the REACH process and will submit registration dossiers within the specified time limits for our tonnage bands.
Morgan Thermal Ceramics have taken the decision to pre-register and register the fibres we manufacture and import into the EU as substances. This decision has been taken following study of the regulation and guidance documents and consultation with the ECHA and leading experts.
Working as part of a technical working group for ECFIA, Morgan Thermal Ceramics, and all other members of ECFIA, have concluded that high temperature insulating wools should be considered substances under REACH for the following reasons:
- RCF and AES are listed in annex 1 of directive 67/548/EEC
- They do not fully meet the criteria for articles as the chemical composition of the fibres can greatly affect the temperature area of ideal application, in order to meet the criteria for articles the following statement must be applicable an object which during production is given a special shape, surface or design which determines its function to a greater degree than does its chemical composition.
The Thermal Ceramics business of Morgan Advanced Materials are committed to meeting our legal obligations under REACH, as a manufacturer, supplier and downstream user. We started preparations for the full implementation of the regulations in 2007 and are active members of several SIEF’s (substance information exchange forums).
All products imported or manufactured within the EU by the Thermal Ceramics business, that meet the criteria for registration under REACH have been pre-registered, this enables us to take advantage of the extended deadlines for registration and ensure that supply to customers is unaffected by the implementation of REACH.
Morgan Thermal Ceramics are also continuing to work closely with suppliers to ensure that the REACH process continues as smoothly as possible, we are communicating with suppliers to ensure that both ours and our customers’ uses are included in their registration documents
How might our customers be affected?
Morgan Thermal Ceramics do not foresee any changes to product range based on the implementation of the REACH regulation, it is hoped that the registration process will provide greater control over chemical substances in the EU, including more complete hazard and risk information following registration. The most obvious change from a customer point of view will be the new MSDS that will become available after the registration process is completed.
The Thermal Ceramics business recommends that customers communicate with all their suppliers to ensure the registration process is being followed where applicable and that their uses are being included in the registration dossier, if your use is not in the registration dossier you will have to submit a Chemical Safety Report to ECHA for your use.