REACH Regulations and Building Limes
A Brief Summary
The REACH (Registration, Evaluation and Authorisation of CHemicals) regulation came into force on 1 June 2007. It affects chemicals manufactured or imported into the EU in quantities of a tonne or more per annum. Because slaking lime involves a chemical reaction, companies making and supplying lime mortars made from quicklime must register with REACH.
To avoid a glut of applications for registration, manufacturers were initially given until 30 November 2008 to 'pre-register', allowing them to produce the necessary registration over a longer period, phased-in according to the tonnage produced and the toxicity of the chemicals involved.
Any company that did not pre-register was required to register from 1 December 2008. Unfortunately very few of the smaller, independent UK manufacturers of lime products understood the full implications of the requirements and missed the opportunity to pre-register. Several of them have now been visited by an HSE inspector and have been given nine months to comply.
Principal effects
- Suppliers of building limes
30-40 smaller companies in the UK slake lime commercially for the production of building limes. Few have pre-registered, and many now face closure if they do not successfully apply for registration. This an expensive and extremely complex process. - Training centres
Organisations slaking over one tonne per year will no longer be able to sell their lime. This material will have to be disposed of as industrial waste by a registered contractor. - Builders and stone masons
Anyone who is slaking lime for resale is likely to be affected by the regulations, including stone masons and other contractors. However, if the contractor is slaking quicklime or hydraulic lime for use on site only, and not for resale, this process is likely to be exempt under Annex V (3), which covers substances which result from a chemical reaction occurring upon end use … and which are not themselves manufactured, imported or placed on the market.
What next?
Suppliers in the south west of England are clubbing together to share the cost of preparing the registration information. Anyone slaking lime who has not pre-registered may be able to join forces with them. For details please contact Peter Ellis at the Rose of Jericho by email (see below).
FURTHER INFORMATION
European Chemicals Agency located in Helsinki, Finland will manage the registration, evaluation, authorisation and restriction processes for chemical substances to ensure consistency across the European Union. Its website provides guidance on REACH – see http://echa.europa.eu/home_en.asp.
Health & Safety Executive hosts the UK's arm of REACH, the 'competent authority' which provides advice though a REACH helpdesk, enforces compliance, and prepares draft decisions on registrations – see www.hse.gov.uk/reach/about.htm.
Building Limes Forum is the UK's organisation for all those involved with the use and production of limes for the construction and repair of buildings. It is hoped that the organisation will help to disseminate best-practice guidance on registration, and its website already provides general guidance from Paul Livesey on REACH registration – see www.buildinglimesforum.org.uk.
Rose of Jericho is one of the lime suppliers affected by REACH who are joining forces to commission the study required for registration. If you are slaking lime for resale in the UK, have not pre-registered, and would be interested in sharing the results, contact Peter Ellis (by email only) at info@rose-of-jericho.demon.co.uk.
For a brief overview of the use of lime in conservation see Lime: the Basics. This and a range of more in-depth articles can be found online at www.buildingconservation.com/articles.htm
