Internally, a REACH Implementation Team has been assembled in the M-I SWACO Corporate Product Registration Group in Aberdeen focusing on REACH.
M-I SWACO will be obligated as:
Although REACH went into effect June 1, 2007, there are only limited obligations until June 2008 when pre-registration begins. As of June 2007, there are requirements for the Safety Data Sheets (SDSs) to be updated (sections 2 & 3 reversed, email address for the competent person added, etc) and our Eastern Hemisphere product registration team has already implemented these changes.
Due to the impact of REACH extending right the way through our business, work has already commenced to engage all groups involved to identify a list of chemicals for which M-I will be responsible for registering with the authorities.
We have been preparing for pre-registration and are working with the steering committee on the list of substances affected. Part of this preparatory work also involves identifying chemicals that are at risk from future supply, either due to hazards posed by the chemical to human health or the environment or economic reasons where the supplier of a chemical potentially walks away from the business. Getting early notice on these chemicals will enable contingency planning to be initiated, resulting in work that may take months, if not years.
M-I SWACO is also a long standing member of European Oilfield Specialty Chemicals Association (EOSCA) and actively participates in the group meetings and REACH Sub Group meetings.