From:
Paul Weller <wellerp**At_Symbol_Here**ELON.EDU>
Subject:
Re: [DCHAS-L] Question about EU REACH intermediate end use registration
Date:
Mar 8, 2023 19:40 UTC
Reply-To:
ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU>
Message-ID:
<PH7PR07MB946760D4107B66415D7EB373DDB49**At_Symbol_Here**PH7PR07MB9467.namprd07.prod.outlook.com>
In-Reply-To:
<414DD146-CDA9-4E48-BDFC-E21B568AA9F2**At_Symbol_Here**ilpi.com>
Fisher sells chemicals from Acros and Alfa Asear (a part of ThermoFisher) which are/were both, at least in part, EU companies. While most Acros chemicals no longer trigger Reach documentation, Alfa Asear has many chemicals which do require
documentation. The latest Fisher on-line catalog does not separate suppliers so you must look at the catalog number to determine the supplier. Acros items begin with AC. Alfa Asear items begin with AA.
If you order an Alfa Asear item from Fisher and it doesn't arrive in a timely fashion, there are two possibilities. One is that you ordered a small package size (“in stock”) which requires scheduling of a fill line to fill the smaller
container (shipping delay). The other is that a Reach form is required but the notification from Alfa Asear to Fisher to the customer failed. If you don’t receive you item, call Fisher customer service and have them call Alfa Asear.
The Reach form must be pasted onto your institution's letterhead before being completed. That instruction isn’t always clear.
Paul Weller
Senior Science Laboratory Manager-Retired
From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU>
On Behalf Of Info
Sent: Friday, March 3, 2023 11:50 AM
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Subject: Re: [DCHAS-L] Question about EU REACH intermediate end use registration
Disclaimer: I am not an attorney and this is not legal advice.
REACH is an EU regulation. The European Union has no jurisdiction within the US any more than, say, China or Russia. You are correct, the PI is under no obligation to comply.
However...
This is strictly a guess: If Fisher got the chemical from a European chemical producer and the EU regulations require that producer to document the end users, then the manufacturer may have contracturally required Fisher to document the
end user. If the PI doesn’t want to sign it, that’s fine, but in this case Fisher wouldn’t be able to sell it to the PI and be in compliance with their sales/purchase agreements. So it’s not the regulations/regulators throwing this at you, but lawyers and
contracts.
I would consider crafting a statement to the effect of “The end use of this chemical is within the United States of America and is not under the jurisdiction of the European Union or REACH.” if you have an objection to signing the Fisher
statement. Or find a different supplier.
A PI had emailed me asking about information on the EU REACH intermediate end use registration that they had to sign in order to get a chemical delivered from Fischer. From the information I’ve seen online, I do not think EU REACH applies
here in the US, but just wanted to make sure as I could not find information in regards to this for the US. The PI asked for protocols for EU REACH but we do not have this and I do not think they need any (beyond the already established laboratory protocols
for handling the chemical). Any information and insight on this would be appreciated.
Amanda Chung, Ph.D. (she/her)
Chemical Hygiene Officer, Environmental, Health, and Safety
UNT Risk Management Services
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