SCHOTT Advanced Optics completes investigations on the registration of its glasses under REACH
In order to comply with the REACH Regulation set forth by the European Union, the SCHOTT Advanced Optics Business Unit has recently completed a thorough review of the legislation’s requirements to determine if our lines of glass need to be registered.
Through diligent investigations and focused teamwork, we determined that the vast majority of our glass products do not require registration. However, for those few glasses that do need registration, the appropriate registration dossier was successfully submitted to the European Chemicals Agency (ECHA) prior to the May 31, 2013 due date.
I. REACH Regulation – Obligation to register glass
Between 2010 and 2013, numerous chemical analyses and leaching tests were performed in order for SCHOTT Advanced Optics glasses to be appropriately classified. We commissioned several independent laboratories, as well as our own externally accredited laboratories, to conduct the tests according to the REACH Regulation and guidelines established by the European glass industry.
To complete the evaluation, glasses were tested after grouping them based on their composition classes and chemical resistance. Using the test results and provisions of the REACH Regulation, we have subsequently divided our glasses into three key categories:
i. Not subject to registration – The vast majority of our glasses fall into this group.
ii. Exempted from registration – Some of our glasses fall into this category due to quantity ranges for production or import, as specified in the REACH Regulation.
iii. Subject to registration – Because of the high lead content, some of our glasses require registration. We submitted the registration dossier to the European Chemicals Agency prior to the May 31, 2013 due date and were assigned the registration number 01-2119990048-30-0000 by the ECHA.
Based on our work, SCHOTT Advanced Optics is now able to provide customers with planning reliability and legal certainty regarding our full breadth of glass product offerings. This information is vital, as it allows our customers to complete their own information requirements along the supply chain in accordance with the REACH Regulation. It is important to note, however, that the results of our analysis and the registration apply to the SCHOTT portfolio exclusively and are not transferable to other glasses on the market.
II. Safety Data Sheet – Technical Safety Information
SCHOTT Advanced Optics has always made safety related information on all of our glass products available to anyone who wants it. This includes information on substance properties, as well as information for safely handling the material. Up to now, the information for all of our glasses was provided on documents known as “Safety Data Sheets”.
According to the REACH Regulation however, material glass does not require Safety Data Sheets, as glass is not:
- Classified as hazardous according to Regulation (EC) No 1272 /2008 (CLP)
- Persistent, bioaccumulative and toxic (PBT), or very persistent and very bioaccumulative (vPvB) in accordance to the criteria in Annex XIII
- Included in the candidate list of substances of very high concern
We believe these sheets are still important, and plan to continue publishing them for our entire line, unchanged in content and format. The only modification will be in name only as the informational sheets for SCHOTT exempt glasses that fall into category i. will now be called “Technical Safety Information”.
Safety Data Sheets will continue to be issued for SCHOTT glasses that fall into categories ii. and iii.. These glasses require a more cautious approach to handling and use because of their composition and chemical resistance, especially in powder form. This is independent of whether the material is processed into a specific powdered intermediate (e.g. solder glass), or is powdery waste generated unintentionally during a machining process.
While the change is based on the new legal requirements, SCHOTT Advanced Optics is dedicated to maintaining the high quality and environmental management standards that we have always abided by. We will continue to fulfill the requirements for Safety Data Sheets as part of the REACH Regulation 1907/2006/EC, through the content and format of our Technical Safety Information materials and Safety Data Sheets. These resources will also ensure SCHOTT meets the Safety Data Sheets requirements set forth by the United Nations Globally Harmonized System (UN GHS) and this information also functions as "Material Safety Data Sheets."
III. REACH Regulation – Our Commitment
The responsibilities of SCHOTT Advanced Optics are defined within Title IV, Articles 31 to 36, “Information in the Supply Chain,” and within Title V, Articles 37 to 39, “Downstream Users.” We are dedicated to utilizing industry best practices, and hereby confirm that we are fully aware of our obligations and of the legal requirement to be compliant with the defined responsibilities. Furthermore, we promise to implement all of the corresponding organizational steps in a timely fashion to ensure compliance with the REACH Regulation.
Should you have any questions regarding the implementation of our REACH obligations, please do not hesitate to contact our global REACH Officer, Dr. Kristian Eichgrün, at this email address: firstname.lastname@example.org.