REACH through the eyes of an SME

Indestructible Paints

Indestructible Paints

• Birmingham based SME• Trading since 1978• Suppliers of coatings to the Aerospace &

Allied Industries, and other bespoke applications

• Stocking facilities in UK, USA, France, India, Singapore, Saudi Arabia

• Exporting to over 40 countries world wide

Major Customers

• Rolls Royce• Turbomeca• ITP• Sikorskey• Mc Donnell Douglas

Boeing• HAL India• Messier Dowty• Honeywell

• Pratt & Whitney• MTU• Allied signal• Eurocopter• BAE• Snecma• Goodrich• Hamilton Sunstrand

Product Types

• Organic coatings, Epoxy, Polyurethane, Acrylic, Silicone modified, Polyimide's, etc

• Inorganic and sacrificial coatings

• Diffusion coatings and Ceramic products

• Intumescent and Thermal Barrier coatings

Where to Start

Two fires and two floods equals incomplete

records.

Then along came REACH

Create a Database

Old school Excel files for:

Raw materials.

Supplier Contacts.

Customer Contacts.

Separate e-mail folders for the equivalent categories.

Collecting Chemical Data

• The critical data for the majority of the RM’s is available from the suppliers

MSDS.

• Data for Substances that we manufacture is affected by the age of the records and

people.

Pre-Registration

• For the majority of our substances Indestructible is a downstream user. To

date we have had a good positive response for pre-registration of our raw

materials.• Pre-registration of the chemicals that we

produce is scheduled for July. Early identification of these materials has

proven invaluable.

Customer Communications

1. Produce a concise covering letter that provides contact details and

data relevant to business continuity.

2. Brief Indestructible staff on the effects of REACH and how to respond to REACH enquiries.

Good Communication

Rolls Royce have the best example to date:

• Phone Indestructible ask to speak about REACH

• Exchange details with the REACH coordinator and exchange

information as required

Messy Communication

• REACH letters addressed to the CEO• This letter was copied by two directors

and a PA.• The REACH coordinator receives three

letters over several days.• The cost of REACH escalates.

• Valid receipt of multiple letters from an organisation can be overlooked.

Indestructible REACH letter

• Our intention to conform to REACH

• Contact details for REACH coordinator

• Position in the supply chain

• Information that we can provide

Examples of information that I cannot supply.

• Provide details of quantities of each substance used in our products across all parts

• Please arrange for a copy of the pre-registration to be sent to me

REACHed the end

Indestructible Paints intends to survive REACH