August – 2017
REACH is a European Community Regulation on chemicals and their safe use (EC 1907/2006). It deals with the Registration, Evaluation, Authorisation and Restriction of Chemical substances. The law entered into force on 1 June 2007. The goal of REACH is to improve the protection of human health and the environment through the better and earlier identification of the intrinsic properties of chemical substances.
Currently the European Chemicals Agency identifies 174 SVHC’s (Substance of Very High Concern) as potentially harmful. In accordance with Article 33 in the REACH regulation, it is our duty to disclose the presence of SVHC’s in excess of 0.1% of article weight. That is the purpose of this statement.
PennEngineering’s current product status as it relates to REACH is as follows:
Standard Cataloged Fastening Products
Most PennEngineering® standard, cataloged fastening products (manufactured at multiple locations) meet the reach definition of an article as outlined above. Therefore for these products, PennEngineering is in compliance with REACH and is not required to withdraw any product because of registration concerns. In addition we have not been informed by any of our suppliers of any raw material withdrawals concerning these products.
Exceptions which contain in excess of 0.1% of article weight of a SVHC include:
– Atlas® brand SpinTite® product types AETA, AETB, AETC, AETS, AEWA, AEWB, AEWC and AEWS 360° swaging style. The standard finish on these products is cadmium which is a SVHC.
– AETA, AETB, AETC, AETS, AEWA, AEWB, AEWC and AEWS 360° swaging style plated with a “9” plating do not contain a SVHC.
– Atlas® brand MaxTite® fasteners with material designation S (steel) and CH (alloy steel). The standard finish on these products is cadmium which is a SVHC. When exposed to certain corrodents such as hydrochloric acid, cadmium chloride which is also a SVHC will form on the surface of cadmium plated parts.
Non-standard, Non Cataloged Products
Certain non-standard PennEngineering products contain cadmium which a SVHC. These include self-locking versions of NASM part number prefixes M45938/7, M45938/11 and any parts with EF, EF-D, C or CI plating suffix. Also included are steel versions of NASM part number prefixes M45938 or M63540. In addition steel and alloy steel material versions of Atlas brand SpinTite® Part with a finish code number of 2 or 7 and MaxTite®, Plus+Tite® or Full-Hex body parts with finish suffix CSI or no finish suffix . All of the above contain cadmium. When exposed to certain corrodents such as hydrochloric acid, cadmium chloride which is also a SVHC will form on the surface of cadmium plated parts. Locking versions of M459038/7 and M45938/11 and any part with EF, EF-D or TE finish suffix also contain the SVHC lead phosphite. For other non-cataloged parts please contact email@example.com.
Going forward, all substances, that require registration, will be pre-registered by our upstream suppliers or us. Subsequently, all substances that require registration will be registered in accordance with REACH.
A corporate REACH coordinator has been appointed at our Galway, Ireland manufacturing facility. They will oversee all REACH relevant activities, including contacting suppliers regarding their intention to register certain substances (where necessary), communicate safety information to employees and customers, and monitor the SVHC (Candidate List of Substances of Very High Concern for Authorization) list for future additions.
Any questions concerning PennEngineering and REACH requirements should be directed to firstname.lastname@example.org
REACH Compliance Team