Hazardous Substances

REACH: Registration, Evaluation and Authorization of Chemicals

This is an EU regulation that places greater on us on, manufacturers, importers and distributors of substances to provide safety data and manage hazards associated with their products.

Registration: REACH registration requires manufacturers and importers to generate data on the substances they manufacture or import and to use these data to assess the risks related to these substances and to develop and recommend appropriate risk management measures.

EACH compliant, its constituent components must be REACH compliant. Where access to the composition is not available for constituent components, supply chains, and suppliers must provide evidence and declarations to prove to their customers that they meet REACH requirements.

Yet, these declarations provide only limited assurance. Chain of custody control should therefore be an important part of any REACH compliance strategy. And, a balanced process of engagement and involvement of the supply chain, supported by auditing and monitoring, needs to be implemented to control risk and costs.

Modi LABORATARY ’s auditing solutions will help ensure that the desired processes and procedures for REACH compliance are being followed. Modi LABORATARY will consolidate the audit findings, and send the customer and the supplier a REACH performance report.

The Modi Laboratary Reach Audit will:

★ Determine REACH-readiness of supplier

★ Evaluate supplier’s methods of information collection and storage

★ Score suppliers for performance against a quantitative set of criteria

If support is needed, Modi LABORATARY can also support suppliers and customers by:

★ Reporting on the presence of Substances of Very High Concern (SVHC)

★ Providing tools to trace the presence of SVHC

★ Ensuring that all chemical information is provided and up to date

PART 1 — Responsibilities and Pre-Registration

★ Analysis of key details related to

★ Sales Channel

★ Supply Chain

★ Products and Chemicals

★ Determination of responsibilities

★ Determination of timelines

★ Creation of compliance strategy Creation of decision tree

★ Pre-registration

PART 2 — Implementation and Compliance

★ Data collection

★ Program Management

★ Data gathering from supply chain

★ Documentation & Testing

★ Registration Dossiers (Technical Dossiers)

★ CSR (Chemical Safety Reports)

★ SDS (Safety Data Sheet),

★ Testing of chemicals and substances including:

★ Physico-chemical Testing

★ Toxicological Testing

★ Eco-Toxicological Testing

★ Registration

★ Registration with the European Chemicals Agency (ECHA)

★ Notification of Substances of Very High Concern (SVHC's)

★ Reporting

★ Reporting of requirements to European Chemicals Agency (ECHA)

TESTING

Based on data supplied, Modi LABORATARY will conduct a screening test for presence of substances of very high concern. This screening test will screen inorganic salts by ICP Technique and the organics by GCMS/MS Techniques.

RoHS / WEEE / ELV and other Directives

New EU legislation have been introduced to reduce environmental pollutants by controlling upstream sources in products and disposal techniques. Primarily, this legislation affects electronics and automobiles and applies only to business done in EU member states. All companies doing business in the EU must comply or face penalties and import restrictions. Some exemptions are granted, but they are limited. Similar laws are being proposed in other parts of the world with the California Electronic Waste Recycling Act SB20/SB50, Japan and China RoHS.

RoHS (Restriction of Hazardous Substances) EU Directive 2002/95/EC New European RoHS directives now severely restrict the presence of Pb, Hg, Cd, Cr6+, PBB & PBDE (Br) in all electro-technical products. In the electronics industry this is the driving force behind Lead-free (Pb-Free) manufacturing.

WEEE (Waste Electronics & Electrical Equipment) EU Directive 2002/96/EC The new WEEE defines strict rules for the recycling of consumer products in the European Union.

ELV(End of Life Vehicle) EU Directive 2000/53/EC ELV is already in effect and seeks to prevent environmental impact of motor vehicle disposal by restricting the same substances called out in the RoHS directives. It promotes design for reuse and recycling, the creation of a recycling program for ELV waste and sets a percentage recycling target for member states.

European Packaging DirectiveEU Directive 95/62/EC EPD seeks to prevent the environmental impact of disposable packaging by restricting Cr(Vi), Cd, Pb, Hgto a total sum of 100ppm…in plastic, cardboard etc. It promotes design for reuse and recycling and covers all (disposable) packaging for food products, consumer goods.

Modi LABORATARY LABS Provides the answer to ensure product compliance. Manufacturers, suppliers and recyclers have to verify compliance by getting it tested on materials and components.

One single technique will not test for all of the substances banned by above directives, these are accomplished by ICP, XRF, UV and GC MASS techniques, all these are available at Modi Laboratary Labs.

XRF screening technique is available with Modi Laboratary and we can even send this portable machine to any manufacturing location for sorting or segregation purpose.

Modi Laboratary can also undertake complete RoHS certification to ensure compliance.

Asbestos Identification by Microscopy

1) Sampling

Asbestos in Soil

Asbestos can be present as contamination in soil where asbestos-containing material has been exposed during a longer time period, or where asbestos has been released by friction and then mixed with the soil. Two types of analyses for soil asbestos samples.

Asbestos fibers in air

The sampling is performed using a polycarbonate filter mounted in a cassette and connected to an air pump. Longer sampling times gives lower limits of detection. The number of particles on the filter must, however, not become too high (the filter becomes stained when the particle density becomes too high).

Only fibers with diameters <3 µm, length>5 µm and length:thickness ratio of at least 3:1 are counted

Asbestos in dust

Take 10-15 cm of tape and fold 2 cm at each end, to hold the tape. Press the adhesive side against the dust. Press lightly with the finger, 2-3 times in the middle of the tape and 1-2 times on the sides, so that a thin, barely visible layer is collected. Then attach the tape sample to e.g. a transparency or a plastic pocket and mark it.

The different microscopic techniques used for asbestos identification are:

❖ Polarized Light Microscopy (PLM ) – This method is for asbestos in bulks present in concentrations greater than 0.5 wt %. Furthermore, PLM analysis can help us classify the type of asbestos present (chrysotile, amosite, crocidolite, tremolite, anthophyllite, actinolite, and Libby amphiboles). However, it fails in samples where asbestos fibers are fine or obscured by tightly binding matrix.

❖ X-Ray Diffraction (XRD) - X-Ray Diffraction ( XRD ) is used for the analysis of free silica, asbestos in bulks, for product identification and for the identification of crystalline phases in general.