Chemicals and other potentially harmful substances in the
workplace are heavily regulated through EU legislation in order to ensure that
they are being used in a way that is safe for people, animals, and the
(or Registration, Evaluation, Authorisation, and Restriction of Chemicals) and
(Biocidal Products Regulation
s) are two of these legislative pieces
but some small businesses face challenges when aiming for compliance with these
The unavoidable bureaucracy involved in meeting the requirements can result in high administration costs. Regulations are complex, and in some cases, businesses will simply choose not to trade with regulated products because they are unsure of how to comply.
What is REACH regulation?
REACH is an EU regulation that came into force in June 2007 concerning the registration, evaluation, authorisation and restriction of chemicals. REACH applies to substances manufactured or imported into the EU in large quantities, although some substances are excluded and covered with more specific regulation instead.
The regulation means that manufacturers or importers are obligated to register their substances with the European Chemicals Agency (ECHA) for them to be legally traded.How each company should comply with REACH depends on where they sit in the supply chain.
According to HSE, the responsibilities of employers and suppliers laid out in REACH regulations will not change once Britain leaves the EU, although minor changes will be made to the regulations to remove EU references. The protection that the laws provide will remain the same as the regulation will be brought into UK law.
What is Biocidal Products Regulation?
The EU Biocidal Products Regulation (BPR) controls biocides. Biocidal products are designed to mitigate the effects of harmful or unwanted organisms through chemical or biological means. They are mainly used by workers to control viruses, bacteria, fungi, insects and animals in the workplace. The BPR revolves around the requirement for biocidal products to be authorised before they can be sold, ensuring that no biocides are particularly risky.
What will happen with BPR after Brexit is not fully clear, but, it’s likely that UK will establish an independent biocidal products regime based off BPR to maintain the regulatory framework. That likely means that the responsibilities of companies that work with these materials will also not change much and the steps that have to be taken for authorisation should remain similar.
The objectives of REACH and BPR
Both REACH and BPR are regulations created and enforced across Europe by the European Chemicals Agency, ECHA. ECHA is the self-appointed ‘driving force among regulatory authorities in implementing the EU’s chemicals legislation’. It aims to benefit both human health and the environment across Europe by providing a framework that makes it sustainable and achievable to manage harmful chemicals.
The potential challenges of REACH and BPR
Complying with REACH and BPR is important, both in terms of staying in line with EU law and in playing a part in reducing the negative environmental impact your company has. There are always challenges involved with becoming compliant with a piece of complex legislation but overcoming them is essential.
REACH presents several potential challenges in that it requires companies to complete registration and authorisation processes for substances that meet just one of the following three criteria:
- Listed in the European Inventory of Existing Commercial Chemical Substances
- Manufactured in the EU but have not been placed on the EU market after 1st June 1992
- Qualify as ‘no-longer polymer’
For companies that use lots of substances that could require authorisation under REACH, the process of registering them could be long-winded, difficult, and expensive. Furthermore, in the event that the substances presented for authorisation are rejected by ECHA, the company is then responsible for replacing them with less dangerous or damaging ones, which again could present logistical and financial challenges.
BPR regulations present challenges that are much the same as REACH’s, as all biocidal products to be placed on the market must be authorised. The authorisation process involves putting together dossiers which include extensive data about the efficacy, physical chemistry, toxicology, and environmental impact of each biocide or family of biocides seeking authorisation.
The potential costs in both time and money that this process could cause companies that are centred around affected products are significant, with each dossier potentially costing up to £150,000. There are also challenges involved in the length of time it could take for substances to be authorised and the halt that would put on the launch of new products.
Usage of plastic, its reduction and regulations
Plastics make up a portion of the chemical products that REACH covers, and they’re a central part of general conversations about sustainability too. Separately from REACH, the UK government has introduced its own legislation that manages the potential harm plastics could have on the environment.
This 25 Year Environment Plan set out by the government includes several strategies to tackle the plastic problem. These include:
- A tax on the production and import of plastic packaging which isn’t made up of at least 30% recycled material, set to be introduced in 2022
- Reforms to the Packaging Producer Responsibility System to incentivise producers to take greater responsibility for their environmental impact
- Working with industry members to rationalise packaging formats and materials to ensure that they’re more easily recyclable
These strategies, along with the updated UK REACH, will help to dictate how companies deal with plastics in the future, hopefully leading to a decrease in the environmental impact that plastic-heavy industries have.
Bunzl CHS’ commitment to sustainability
Bunzl has focused on sustainability since 2005 and, with a five-pronged approach, looks at waste, water, electricity, carbon footprint, and product sourcing in order to lead the way as an environmentally-conscious business.
As part of the FM Supply Chain Sustainability School, Bunzl CHS can share best practice with other School members. We take a proactive approach and train staff on environmental impact, so that they’re passionate about implementing positive changes.
Through Innov8, Bunzl CHS searches for products that move the cleaning industry forward in terms of sustainability. Many of these products are chemical free, packaging is bio degradable and use plant-based enzymes. Choosing to supply sustainable products is a great way to ensure that our approach trickles down.
Our 5 top business sustainability tips
Invest in proper recycling infrastructure so that recycling is standard practice throughout your business. This can result in huge reductions in the amount of waste you send to landfill – we managed to cut our landfill waste from 417,000 tons in 2005 to 73 tons in 2017.
Responsible water use is at the centre of sustainability and finding ways to reduce the amount of water you use in your business is a great way to decrease your environmental impact. Tips for achieving this include installing dual flush toilets, staying on top of any leaks, and monitoring your usage.
Use renewable electricity
Fossil fuels are damaging to the environment and they’ve been a much-maligned traditional resource for years now. If you can manage to source your energy from alternative means, such as windfarms or hydro-electric plants, you’ll be cutting your carbon footprint. At Bunzl, we have sourced 85% of our electricity from 100% renewable tariffs since 2012.
Carbon footprint monitoring
There’s a lot to keep track of when you’re trying to reduce your environmental impact as a business but monitoring your overall carbon footprint can give you a top-level view of how successfully you’re cutting down on bad practices. Since 2013, we’ve overseen a 25.8% reduction of CO2 emissions per delivery cause.
Finally – if you’re serious about making a positive change to the impact your business has on the planet – keep up with and invest in new technology to assist your cause. We fitted all of our vehicles with telematics technology in 2011, resulting in a 20.6% reduction in fuel usage per £1M turnover.