LOBBYING
Sector-Wide Lobbying Activities & Support
Health & Safety Directed by Wayne Smith BCF’s Safety Advisory Panel reviewed and updated industry guidance, including: spontaneous combustion; the safe handling of flammable liquids; spillage, including floor cleaning; and the raw material hazard coding scheme. Loss of containment and other process safety indicators were being developed for the industry. The Panel continued reviewing company incident reports and issuing relevant ones to the industry. Liaison with the HSE continued through the Chemical and Downstream Oil Industry Forum and the Small Business Trade Association Forum, as well as through individual contacts.
Classification and Labelling Directed by Wayne Smith The Classification, Labelling and Packaging of Substances and Mixtures (CLP) Regulation (1272/2008 EC) has been introduced, aligning EU legislation with the UN Globally Harmonised System for the Classification and Labelling of Chemicals (GHS).The new scheme will affect all inks and coatings supplied in the EU. GHS represents the goal of a single worldwide system for classification and hazard communication in the transport, supply and use of chemicals.
From 1 December 2010, substances had to be labelled in accordance with CLP, including new hazard and precautionary statements, with new hazard pictograms. Mixtures, such as inks and coatings, must be classified and labelled to the new criteria by 1 June 2015. Members were brought up to speed with the requirement to notify the classification of any substance they import, either as a substance, or in a mixture/product.
Environment Directed by Wayne Smith The Environment Panel continued its stewardship of all aspects of air emissions, waste and water issues. This included the review of the Process Guidance Notes, the disposal of emptied packaging and the effect of the new EA fines for
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environmental
breaches.The developing waste framework was monitored and contributed to.
Discussions with DEFRA and the EA resulted in the removal of powder coating production from legislative controls as long as this did not involve lead or TGIC. This was supported by an industry- written code of practice, which is now available on the BCF website.
In addition, BCF has submitted data for predicted emissions up to 2020 to help DEFRA in its discussions on the National Emissions Ceiling Directive revision. Also under close scrutiny was the revision to the Sector Guidance Note SG6 on solvent use and the recasting of the IPPC Directive as the Industrial Emissions Directive.
Transport and Packaging Directed by Wayne Smith and Nigel Rose The Carriage of Dangerous Goods Panel continued to monitor new papers to the UN, ADR and IMDG Code committees. In conjunction with CEPE, proposals were submitted to the UN committee regarding environmentally hazardous products and Packing Instructions for UN3269. Opposition was raised against a Korean paper on the proper shipping name for UN1263. Discussions were also held on the shipment of paint sold on the internet.
Guidance was issued including a revision to the BCF Guide to CDG etc and a revised version of Packaging Options
Guide.Transport Alerts were issued on Limited Quantity marking and vehicle requirements; the packaging of environmentally hazardous liquids for air from 2011; the 2011 changes including the new Limited Quantity pro- visions; and changes to documentation for waste paint. Security as an issue was monitored through TRANSEC with the BCF contributing its position on security controls and circulating guidance.
REACH Directed by Wayne Smith By the REACH deadline of 30 November 2010, 24,675 registration dossiers had been successfully
British Coatings Federation Annual Handbook & Membership Directory 2011
submitted for 4,300 substances. We are still waiting to see if there is a significant disruption to the supply of raw materials to the industry. ECHA’s website will regularly update the numbers and identities of registered substances. Members were informed that they could continue to use any substances that were bought before 1 December.
Members are starting to receive exposure scenarios for substances that have been registered. One concern is the number of pages and variations in the format of Exposure Scenarios attached to Safety Data Sheets. BCF members have been kept advised of the situation with regular bulletins from both BCF and CEPE. These included a Briefing Note of the format and content of an exposure scenario and broad guidance on where to find information to enable companies to fulfil their REACH obligations and a list of questions and answers that companies might ask. The identification of Substances of Very High Concern (SVHCs) that will be added to the Candidate List and may thus become subject to Authorisation continues. BCF is keeping members informed as substance lists are issued.
Standards Directed by Hugh Williams The BCF has continued to play an active role in a range of standards committees representing the wide interest that members
have.The BCF members are not only involved in BSI work but also in European (CEN) and international (ISO) standardisation.
Areas where activities are currently concentrated are for inks in packaging and the environment, development of intumescent coatings standards for Europe and on the methods for assessing releases from coatings into indoor air.
The BCF issues its annual report of standards issues activities that are relevant to members, as well as keeping members updated through the quarterly BCF Digest.
www.coatings.org.uk
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