Frequently asked questions

We have carefully and systematically identified our obligations under REACH and developed a strategy for ensuring that we fulfil them in a timely and efficient manner. To oversee our REACH implementation plans, we have established a dedicated REACH project team, which is led by a full-time senior REACH Manager.

REACH does affect Tata Steel as an Importer from outside the EU, Manufacturer, Downstream user and Distributor of substances, on their own, in preparations and in articles.

The purpose of the REACH regulations is to ensure a high level of protection of human health and the environment, including the promotion of alternative methods for assessment of hazards of substances, as well as the free circulation of substances on the internal market while enhancing competitiveness and innovation.  The Regulation is based on the principle that it is for manufacturers, importers, downstream users and distributors to ensure that they manufacture, place on the market or use such substances that do not adversely affect human health or the environment.

The REACH team is led by the Senior REACH Manager and is supported by 3 team members.  Each team member is the REACH team contact for specific businesses of Tata Steel; this covers the large manufacturing sites, downstream production sites, distribution centres and specialist product sites. 

The team also run the REACH helpdesk, which acts to assist any REACH query from outside or inside the company.  The Corporate Environment department has responsibility for assisting businesses with REACH throughout the company.

Every Business Unit has it’s own REACH coordinator to make sure the Business Unit specific issues are covered.

Yes that’s right.  One of the aims of REACH will be to remove dangerous substances from the market in the case of human health and the environment.

Certain substances will be put forward for what is known as Authorisation and furthermore could be restricted by the European Chemicals Agency (ECHA).

The REACH team are monitoring the ECHA correspondence to identify substances on the authorisation list, which will be listed in Annex XIV. The first so-called candidate list was published in the end of 2008 and consisted of 15 substances. As soon as you sell one of these 15 substances as such, in a preparation or in a concentration above 0.1% weight/weight in an article, you are obliged to give your customer information about the substance so the customer can use it in a safe way.

A selection of this candidate list will be in Annex XIV. The REACH team will activate specialists within the company to assist us to scrutinise the consequences of these substances listed. If the substances are on Annex XIV we might have to source alternatives to allow the company to continue to produce our range of products.

View the list of substances that have been placed on the candidate list on the ECHA website.

Dangerous substances do have obligations regarding both registration and communication under REACH.  Communication of information relating to dangerous substances is very important.  Although not as strict and intensive the requirements for passing information on to customers of dangerous substances is required.

To allow customers / users of substances which are dangerous a series of exposure scenarios will be created covering all the uses of the substances and identify how exposure could occur and how to apply risk management measures to eliminate or reduce exposures in that operation.  For dangerous substances an extended Safety Data Sheet (SDS) is required.  In the annex of the SDS all the exposure scenarios should be collated to give the best advice possible to the downstream user of the substance.  Information on the dangerous substance will also be communicated in the main body of the 16 point SDS detailing its hazard classification, toxic / dangerous effects to both humans and the environment and any risk management measures that can be used to reduce exposure.

There are a number of specific duties that must be met in terms of notifying the European Chemicals Agency (ECHA) and supplying downstream users with the relevant information as well as the general registration requirements of REACH.

Article 7 of REACH lays down an obligation relating to notifying ECHA of SVHC in the articles that are manufactured and or an import. This will start 2011. See article text below:
Article 7 – 2. Any producer or importer of articles shall notify the Agency, in accordance with paragraph 4 of this Article, if a substance meets the criteria in Article 57 and is identified in accordance with Article 59(1), if both the following conditions are met:
(a) The substance is present in those articles in quantities totalling over one tonne per producer or importer per year
(b) The substance is present in those articles above a concentration of 0,1 % weight by weight (w/w).

With respect to communication obligations, Articles 33 and 32 give a number of duties for manufacturers and importers to perform so that information of the SVHC is clear for downstream users to use. This obligations has to be fulfilled as soon as a substance is on the Candidate list – The words of Article 33 is below:
Article 33 –

1. Any supplier of an article containing a substance meeting the criteria in Article 57 and identified in accordance with Article 59(1) in a concentration above 0,1 % weight by weight (w/w) shall provide the recipient of the article with sufficient information, available to the supplier, to allow safe use of the article including, as a minimum, the name of that substance.
2. On request by a consumer any supplier of an article containing a substance meeting the criteria in Article 57 and identified in accordance with Article 59(1) in a concentration above 0,1 % weight by weight (w/w) shall provide the consumer with sufficient information, available to the supplier, to allow safe use of the article including, as a minimum, the name of that substance.
The relevant information shall be provided, free of charge, within 45 days of receipt of the request.

Generally information about substances will be available in a Safety Data Sheet (SDS) so that downstream users can use for their uses.  Information on SVHC will also be included in the SDS, but if a SDS is not required Article 32 requires manufacturers or importers to supply information to their downstream users.  Our suppliers are not obliged to “label” substances as SVHC in their communication. In case you import substances, preparations or articles, you have to check by yourself whether there are SVHC involved. This could be done by requesting your non-EU supplier to answer our standard letter about containment of SVHC. Please see the Article 32 text below:

Article 32 – 1. Any supplier of a substance on its own or in a preparation who does not have to supply a safety data sheet in accordance with Article 31 shall provide the recipient with the following information:
(a) The registration number(s) referred to in Article 20(3), if available, for any substances for which information is communicated under points (b), (c) or (d) of this paragraph;
(b) if the substance is subject to authorisation and details of any authorisation granted or denied under Title VII in this supply chain;
(c) Details of any restriction imposed under Title VIII;
(d) Any other available and relevant information about the substance that is necessary to enable appropriate risk management measures to be identified and applied including specific conditions resulting from the application of Section 3 of Annex XI.

Both ECHA and Member States have the opportunity to propose a SVHC dossier for inclusion in Annex XIV.  The proposed SVHC dossiers will meet the requirements of Annex XV and will be placed on the ECHA website for comments from Member States and once the comment period is over it will then be decided if the SVHC will be added to Annex XIV Substances subject to Authorisation.  This will all be indicated via communication from ECHA and documents placed on the ECHA website.  If a substance is not selected for Annex XIV then it will remain on the Candidate list until the next substance review.  It is likely that a review will take place at least every 2 years. 

Each substance will also be given a date in which placing on the market and the use of that substance shall be prohibited.  This date is known as the “sunset date”. For the production or use of an Annex XIV substance to continue an application for Authorisation must be applied for so the substance can be manufactured, imported or used under certain conditions.  The decision on the granting of authorisation sits with ECHA.  The company may be asked to look at substitution and put in place a substitution plan to use a less dangerous substance. The period between being put on Annex XIV and the sunset date is about 3½ – 4 years.

Yes, REACH has a formal list of exemptions:

• Radioactive substances
• Substances under customs supervision 
• The transport of substances 
• Non-isolated intermediates 
• Waste 
• Some naturally occurring low-hazard substances

Some substances, covered by specific legislation, have tailored provisions, including:

• Human and veterinary medicines 
• Food and foodstuff additives
• Plant protection products and biocides

Also Annex IV and V, which have already been revised in 2008, contain relevant exemptions for registration, like: hydrogen and oxygen and the following substances if they are not chemically modified: Minerals, ores, ore concentrates, raw and processed natural gas, crude oil, coal, liquefied petroleum gas, natural gas condensate, process gases and components thereof, and coke. 

Read Annex IV and V.

Scrap will have to be dealt with like other recycled substances. Tata Steel has pre-registered the useful constituents, but won’t register these substances (unless this is needed because of other reasons, like we will register iron because we produce it).  If developments under the Waste Framework Directive change the current waste status of scrap by changing the point of recovery in the steel plant, this could influence the need to register under REACH (e.g. if scrap becomes a preparation instead of a waste, we might have to register the useful constituents in case of import from outside the EU).

Mostly they don’t but on occasion a registration may be required.  Substances, on their own, in preparations or in articles, which have been registered, are not required to be registered if the substance that results from the recovery process is the same as the substance that has been registered (if generated within EU).  It is possible that in some cases the recovered material will NOT be the same as the registered material. In those cases the substance will be required to be registered. The reason is that the recycler would now be considered to be the producer/manufacturer of a substance and would therefore have an obligation to register that substance.

Safety Data Sheets (SDS) will essentially remain but will follow a different format.  REACH along with a new set of regulations called CLP (Classification Labelling Packaging Regulations 2009).  The REACH team are establishing a plan on how we can update our SDS to the new correct REACH and CLP format.  The REACH team will work with all the Business units to make sure all the SDS can be upgraded and converted covering all the new requirements.  Currently there is a trial of three SDS to show what work is required to cover the whole of the UK as a start.

This change of format will also be seen in the SDS we receive for the products we are supplied and use within the manufacturing process.  Some SDS depending on the substance involved will also have an extended annex available that will contain much more information than is currently available such as toxicity reports and exposure scenarios along with risk management measures.  This extra information contained within the annex will allow the users of the substances to carry out efficient Risk (COSHH) assessments to maintain a safe use of that substance in terms of human health and the environment. Although REACH has no SDS-obligations for articles CLP does have a requirement for "Metals in Massive form", so we will continue to provide SDS to our customers of our steel.

No, Corus produce or import a number of different items under REACH.  We produce or import substances, preparations and articles.  Examples are listed below:

• Substances = Iron, Ammonium Sulphate, Sinter, Tar, Pellets, Crude benzole
• Preparation = Most Metallic Alloys (not manufactured by Corus but imported), 
• Articles = Bloom, Slab, Wire Rod, Coil, Sections, Plate, Tubes, Panels, Refractory bricks

Steel is not a substance, but a special preparation and it will be the constituent elements that will require registration; e.g. the iron, nickel, chromium etc. that make up the alloy. The question is when the preparation becomes an article. First cast products have been defined as articles under REACH.  Steel products once cast either by continual casting or into an ingot is the last time the chemical composition changes within the steel (unless the ingot is cast for re-melting or has no specifications at all).  An article is defined as an objective, which during production is given a special shape, surface, or design, which determines its function to a greater degree than does its chemical composition. 

Read the final EUROFER position, which has now been submitted to ECHA for inclusion in the official ECHA Guidelines.

Tata Steel carefully selected all the manufactured substances it would like to register by the first deadline of the 30th Nov 2010.  Many of the substances that were pre-registered were done so on a precautionary basis to secure the supply chain and won’t be taken through to a full registration.  The main reasons for this decision is that there is no need to produce a full registration and there will be a large financial cost. 

In fact the number of manufactured substances that the company aim to register under REACH is currently 14.  This may change as certain positions may be brought forward by Corus and other parties and it may be decided to register substances that were thought to be outside the scope of registration.  In the table below you will see the substances, the relevant consortia and the business units who manufacture the substance.  Corus will also register some imported substances like manganese, ferro-silicon and chromium.

* TSSPUK = Tata Steel Strip Products UK; TSSPIJ = Tata Steel Strip Products IJmuiden; LPB = Long Products Business; TSS = Tata Steel Speciality; TSP = Tata Steel Packaging; TSC = Tata Steel Colors; TCP = Teesside Cast Products. 

Within the REACH process and the text of the regulations it states that dossiers should be prepared by a Lead Registrant for each substance and that sharing of information should be carried out within a Substance Information Exchange Forum (SIEF).  In principal the Lead Registrant will organise all the work that is required to produce the registration dossier ready for the deadline.  This work will consist on a data gap analysis of existing data, organising meetings between all parties concerned, inputting part of the data in the computer system (IUCLID V) and often producing the Chemical Safety Report (CSR) and many other tasks. 

In reality registration this is an enormous undertaking, which will take a large effort from one Lead registrant.  What we have seen is the establishment of consortia for particular substances.  These consortia along with the Lead registrant and the other parties concerned will work together to produce the registration dossier.  The Consortia will manage the project and put in place a lot of the work that needs to be done for example, bring consultants on board, organising meetings, sending communications and assisting in the preparation of the dossiers as well as supporting the roll-out of the joint submission of the dossiers of all its members.  Tata Steel have become full members of 4 consortia and are taking the lead in one of them: the Iron Platform (Iron, Iron sinter, Pellets, Fe2O3).  Tata Steel has the opportunity to be active in all the consortia for each substance it wishes to register.  However it is also possible to remain dormant in the process and allow the experts in a particular field to do the work and just receive the dossier at the end.  This is called Letter of Access and will be discussed further in its own FAQ.

Within REACH it is written that someone should take the lead for each particular substance to be registered by the relevant deadline.  In principal the Lead Registrant will organise all the work that is required to produce the registration dossier ready for the deadline. 

This work will consist on a data gap analysis of existing data, organising meetings between all parties concerned, inputting part of the data in the computer system (IUCLID V) and often producing the Chemical Safety Report (CSR) and many other tasks.  The lead registrant will also be the first to submit the registration dossier to ECHA for their particular substance.  Once this has been received and acknowledged they will then give all the other registrants an access key to use the dossier for their own registrations.  

Tata Steel is the proposed lead registrant for Iron Sinter and Iron Ore Pellets and is working in conjunction with the Iron Platform consortium.

Tata Steel has set up a dedicated website for REACH explaining how the REACH team will go about implementing the requirements of REACH.  On the website the REACH team will place communications such as letter, statements or position papers relating to different subjects of REACH.  This will happen when the REACH feel that it would be beneficial to update our suppliers and customers.  These communications can be downloaded as pdf files for reading.

Tata Steel also have REACH activated members of our Supplies and Commercial teams who will be able to deal with queries and provide answers to simple queries.  This contact should be carried out through your personal account contact that you have with the company. 

If you query is more technical then please email the REACH helpdesk.  We will then be able to deal with your request and give you a full detailed answer to your query / question.