Frequently Asked Questions (FAQ’s) about LSM and REACH
1. Are LSM products affected by REACH?
Yes, the new REACH legislation covers chemicals and this includes metals and alloys. Therefore we will be working to ensure the company is compliant regarding the substances in our products.
2. How has LSM prepared for REACH?
We have formed a REACH implementation team who ensure that the company is compliant with the new legislation. They are actively involved in preparing registrations of substances that are essential for the continuity and growth of our business.
3. Which substances has LSM pre-registered?
In the interest of business continuity, the primary objective is to ensure that all substances that are components of our products, or are used in our manufacturing processes and that will later require registration have been covered by pre-registrations.
4. Are there any substances LSM does not plan to pre-register?
Not at this stage. We aim to pre-register all relevant substances.
5. Which substances does LSM plan to register?
We will aim to register all substances that we manufacture or import from outside the EU. If there is a reliable supply of raw materials within the EU, and the supplier can demonstrate that the substance in question has been registered, then we may consider that registration is not required.
6. Are there any substances in our products that are likely to be banned / restricted?
At present we are not aware of any substances that are likely to be banned or restricted. However, substances are being re-classified as a result of REACH and the list of substances of very high concern (SVHC’s) and the list of substances requiring authorisation is being updated constantly. We will advise customers if any of our products are affected by new developments.
7. What is LSM’s role in REACH?
The company has various roles under REACH. As a manufacturer/ importer we have an obligation to register substances that we manufacture or import into the EU.
As a downstream user we have an obligation to ensure that substances supplied to us have been registered by a party in the supply chain.
As a supplier we have an obligation to communicate any relevant safety information regarding the use of the substances in our products to our customers. This is achieved through labelling and a safety data sheets.
8. Are there any products produced by LSM under risk?
At present we are not aware of any products that are at risk from the new legislation. If you are buying a product or are considering buying a product in future from us, then please contact us to confirm that the substances in your product(s) will be, or have been, registered.
9. What deadlines are LSM working to?
After successfully registering our high volume substances in 2010 we are now working towards our 31st May 2013 and 31st May 2018 deadlines.
10. Are LSM working with any trade associations and consortia with regards to REACH?
We are working with various trade associations, consortia and working groups to prepare for registration and we play an active role in these ventures. We also seek guidance from the Health and Safety Executive (HSE) also employs REACH consultants as and when required.
This is especially important if your use is unusual because if it is not described in our registration application we cannot supply you with our product.
11. Will LSM cover customer downstream uses within its registration?
We request information on the uses of our products from our customers by questionnaire and this is incorporated into our registration application. It is important that customers provide information to us so that we can build a database of customer uses and likely exposure scenarios.
12. Will LSM amend its Product Safety Data Sheets to comply with the new regulation?
Yes, we have updated the format of our safety data sheets to comply with REACH legislation. These will continue to be adapted as a result of re-classification or when new data on potential hazards becomes available.