Environment
European Regulation
"REACH" No. 1907/06
R.E.A.CH - acronym stands for Registration, Evaluation, Authorization and Restriction of Chemicals. The European Regulation no. 1907/2006 “R.E.A.CH” replaces many former E.U. rules on chemicals, and complements the environmental and safety legislation in force.
RIVA Group has been closely following the development of the REACH Regulation since its early enforcement, fully committing to the industry’s duty to prove that the substances produced, imported, and used, are chemically safe for human beings and for the environment. The assessment, registration, authorization, and restriction of chemical substances, along with their safe use, are all processes covered within regulatory compliance.
The management of RIVA Group has allocated financial and human resources necessary to ensure the implementation of the Regulation. The new principle, "no data no market", calls for a comprehensive and integrated approach within the organization, engaging at central level and production sites to secure business continuity and prevent any disruption in key processes, such as purchasing, manufacturing, and placing steel products on the market.
REACH itself, by its very nature a regulatory tool binding all the European Union Member States, requires steering and coordination in the compliance of all our Europe based companies, taking into consideration the specifics of each single business and the national regulatory framework of their operations. Under REACH Regulation the legal entities of RIVA Group may play different roles at a time, as manufacturer, importer, and downstream user.
To the steel industry, the year 2010 represented a time of major challenge and effort with a November 30th deadline to register substances produced and/or imported in quantities above the 1000 tons threshold. RIVA Group registered 10 substances by submitting to ECHA some 16 Registration Dossiers. In particular, the substance iron (Fe) Einecs number 231-096-4 / CAS number 7439-89-6 was registered in joint submission with the Sief appointed Lead Registrant and the technical and scientific advice of the consortium Iron Platform Services Ltd (http://www.iron-consortium.org.) Compliance to the notification requirements under the new EU Regulation on Classification, Labeling and Packaging (CE) 1272/2008 CLP was ensured as well.
In 2011 and currently, regulatory compliance is directed to focus on implementing management system actions so the principles of the European Regulation on Chemicals are embedded in day-to-day practices and become part of working procedures. The dissemination of information within the company and up and down the supply chain (with suppliers, customers and stakeholders at large) is constantly tracked, with the ultimate goal of raising awareness of the dangers involved with chemical products and to ensure the appropriate management of risks. Whenever needed, their substitution with technically and economically viable alternative solutions will be actively sought.
Our steel products, as listed in the dedicated section “Products and Services” of the website, are defined by REACH as “articles” (Art. 3, paragraph 3). EUROFER, The European Association of Steel Industries, on the basis of the interpretation of the ECHA-Agency “Guidance on requirements for substances in articles” in particular as clarified in Annex 3, considers steel products as articles “without intended release of substances under normal or foreseeable conditions of use” and as such, they do not fall under the obligation of registration (Art. 7, paragraph 1, letters a and b).
As for the obligation to communicate information on the substances contained in articles (Art. 33), we confirm that no SVHC substance included in the latest update of the Candidate List for final inclusion on Annex XIV is contained in our steel products with a concentration > 0,1 % w/w of the whole article. As it evolves, the Candidate List is being regularly monitored, and where relevant, any information of consequence is given to our customers on the dedicated REACH Documents and Contacts section of RIVAGROUP website.
Our organization confirms its total commitment to ensure full compliance, dissemination of relevant information all along the supply chain, and throughout the operations of our company units.