Taking exception to REACH Requirement - Appropriate Language

normzone

Trusted Information Resource
#1
A major aerospace outfit has begun including a caveat in T&C that says they can come back for REACH certification at any time on down the road regarding the order.

So far when we push back the customer has been waiving this, but I've been tasked with creating a boilerplate statement taking exception to this requirement for Sales to use.

Does anybody have suggestions for appropriate language or statement? If you don't have a complete example, I'll happily accept suggestions for bits or pieces - a phrase or a sentence I've not thought of could make my life easier.

As always, thanks for all you do here - :applause:
 
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Marc

Hunkered Down for the Duration
Staff member
Admin
#2
A quick "Bump". My Thanks in advance to anyone who can help with this unanswered question. And, should you be browsing threads and find this one, and it still has no reply, if you can help we will all appreciate it.
 

normzone

Trusted Information Resource
#4
Amusing that this thread should surface today.

I came in to an email asking " what about that REACH statement? "

I reminded them that I wrote a piece of hand waving text amounting to " these are not the droids you're looking for " and top management was not satisfied with it, and it was agreed we would begin designing to meet the requirement.

Yes, you probably have the same customer.
 

Alex73

Starting to get Involved
#5
According to REACH / CLP, the Safety Data Sheet should be provided in official language where the product will used.
To comply with article 33 of REACh (when a SVHC is present on a concentration above 0.1%) the minimum information to be provided is the name (here I also would assume that should be in the official language of the country using the articles).

Long time ago, I came across the information that the official REACH regulation text language is the English.
Thus, in presence of translation doubts the English text would prevail [but I cannot find where I read that].
However, with the BREXIT, it is likely that the English will no long be an official language!


In my opinion, you should have the documentation in your local national language (process safety, audits, etc), in the language of the country where the product will be used (because REACH/CLP says so) and in English (because it is most common spoken language). :)

Alex.
 
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