Paul McManus here with an update following a conference call I had last week with the Doctors and Scientists of REACH…
- There is new ECHA (European Chemicals Agency) guidance being published in the near future relating to products coming into direct and prolonged contact with the skin, specifically Nickel and Nickel compounds
- The issue itself is not a new one and EU articles on this matter go back to the mid 90’s
- The new guidance (nb not guidelines, there is a significant difference) is likely to create fresh “interest” in the matter and does mention our industry as having products that CAN (not will) cause allergy issues
- Guitar strings, trumpets and trombones are specifically mentioned
- The actual official nickel restrictions are related to the “release rate” at which the nickel comes into contact with the outside of the skin
- There are also mentions of the “absorbtion rate” at which the nickel actually “enters” the skin, but these are not the focus of the official restrictions
- There is also information on prolonged contact with the skin which talks about 10 minutes of CONTINUOUS contact with the skin (more on this later)
THE GOOD NEWS
- All of this legislation is seen in the context of RISK rather than HAZARD……that is good news for us (it is not as “serious”)
- That means our duty as an industry is to be aware if our products are likely to cause a problem of not (and to naturally take action if they are!)
- As an example, we could say that a guitarist is unlikely to be continuously touching the strings for 10 minutes?
- On that basis, the nickel content should not be an issue to anyone with any degree of nickel sensitivity?
- Equally, the knowledge that our brass mouthpiece (which contains nickel) has a silver coating of 10 microns that should mitigate against most levels of human nickel sensitivity?
- However, the cheap import mouthpiece with only 0.1 micron of plating may fall far short of the guidance?
WHAT TO DO WITH ALL OF THIS
- DEFRA are the lead body in the UK on these matters
- Trading Standards would be the people investigating you if (say) a customer made a complaint about a product of yours that affected them
- YOU need to show that you have considered your products that use Nickel or Nickel compounds and have determined that they are not at any significant risk of causing allergy problems
- This is obviously trickier for certain products and you may need to consider having them tested (eg the silver plating thickness mentioned earlier)
- We have details of the specific tests that needs to be taken if you need it…BUT, be warned the tests cost and are normally to product destruction!
- And here is the current DRAFT ECHA guidance document:
- And here is the current ECHA restrictions document:
This matter is clearly not currently a big issue for our sector or it would have raised its’ head more over the last 20 years when the original legislation was introduced
The new guidance is likely to create some degree (or not) of new interest and it seemed sensible to take advice from REACH and to inform you all?
I will let you know when the final guidance is published
Contact me in the meantime if you need MIA support, email@example.com