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G.L. Huyett REACH Compliance Statement


REACH Compliance This page is provided as the official Policy Statement for Flinthills Trading Company, a Kansas corporation doing business as G.L. Huyett, in regards to the European Union’s issuance of directive EC 1907/2006 that deals with chemicals and their safe use. This directive deals with the Registration, Evaluation, Authorization, and Restriction of Chemical Substances within the European Union (hereinafter referred to as “REACH”). G.L. Huyett has carefully researched and studied the regulations, and can therefore offer the statements and claims contained within this document.

 

1. Definitions of REACH

As defined by the European Commission: “REACH is the European Community Regulation on chemicals and their safe use (EC 1907/2006). It deals with the Registration, Evaluation, Authorization, and Restriction of Chemical substances. The law entered into force on June 1, 2007. The aim of REACH is to improve the protection of human health and the environment through the better and earlier identification of the intrinsic properties of chemical substances. The REACH Regulation places greater responsibility on industry to manage the risks from chemicals and to provide safety information on the substances. Manufacturers and importers are required to gather information on the properties of their chemical substances, which will allow their safe handling, and to register the information in a central database run by the European Chemicals Agency (ECHA) in Helsinki, [Finland]. The Agency acts as the central point in the REACH system: it manages the databases necessary to operate the system, coordinates the in-depth evaluation of suspicious chemicals and is building up a public database in which consumers and professionals can find hazard information.

The Regulation also calls for the progressive substitution of the most dangerous chemicals when suitable alternatives have been identified. For more information visit this link to read REACH in Brief.

One of the main reasons for developing and adopting the REACH Regulation was that a large number of substances have been manufactured and placed on the market in Europe for many years, sometimes in very high amounts, and yet there is insufficient information on the hazards that they pose to human health and the environment. There is a need to fill these information gaps to ensure that industry is able to assess hazards and risks of the substances, and to identify and implement the risk management measures to protect humans and the environment.”

2. Definitions of IMDS

IMDS is the International Material Data System, a global data repository for product content used by the automotive industry and used to gather information for use in reporting requirements for directives such as REACH. It is the global standard for the industry and has been in place since the 1990’s with over 90,000 participating companies and suppliers. Because it is a computer-based system, IMDS recognizes hazardous substances by comparing the entered data with the lists of prohibited substances. Hence OEMs can trace hazardous substances back to the part and work on eliminating them through the supply chain.

All substances have to be stated in the material data sheet (MDS) of the IMDS with a resolution of 1 gram or better - not just the declarable and prohibited substances (Cr VI, Hg, etc.). That is why substances and materials of products must be known in detail.

The basic premise of the system is that the flow of data through IMDS companies mimics the flow of the product through companies in the physical world with each link in the supply chain supplying data in IMDS to their customer as they deliver product to their customer.

3. Limited Warranty

Products purchased from G.L. Huyett by Buyer may be manufactured by third parties who may or may not provide a warranty to the purchases of their products, comply with REACH directives, or have control over raw materials and suppliers, even if warranties are provided to G.L. Huyett as they may not be accurate or reliable. G.L. Huyett agrees, upon request from the Buyer, to assign Buyer any and all such warranties without recourse. G.L. Huyett warrants that all products shipped against an approved purchase order will conform to specifications and drawings submitted and that such products will be manufactured and inspected according to generally accepted applicable practices of companies manufacturing industrial fasteners. All warranties provided by G.L. Huyett to its customers are subject to the G.L. Huyett Terms of Sale.

Where possible, and when requested by the Buyer, G.L. Huyett will use the IMDS database and other approved sources to confirm and disclose the chemical content of all requested parts. However, G.L. Huyett may not perform chemical testing of their own on any raw material or finished good that is processed through our facilities, but instead rely upon the representations and warranties of approved suppliers of G.L. Huyett. G.L. Huyett cannot be responsible for slight differences and variations between part lots.

When provided, the chemical analysis of any given part should be considered a typical analysis of that part, and not necessarily an exact analysis of the part that is shipped. This information is provided based on typical analysis for the materials used in the manufacture of the product. Slight deviations may exist from lot to lot as acceptable production standards that exist during the manufacturing process. Trace amounts of unknown chemicals can be introduced during refinement, delivery, processing, and manufacturing such as household chemicals, pesticides used to fumigate pallets against contraband organisms, and other chemicals introduced by shippers during transit from our dock to the Buyer.

G.L. Huyett is not responsible for any chemicals that may come into contact with our raw materials or finished goods at any point that said materials or finished goods are not located within our facility. This includes, but is not limited to, transportation of raw materials or components from our supplier to our facility, transportation of goods or materials from our facility to a third party facility for additional processing, or the shipment of our finished products from our facility to the final destination of the goods as determined by the Buyer.

The only means to be absolutely assured of the specific and precise chemical contents of a particular shipment is to test all components of a finished good prior to commencing the manufacture of each part, then manufacture the parts in a clean room and ship them in air tight, sealed vessels to the point of use. Such process is not commercially reasonable given the unit cost of most products and thus this warranty provides a practical application of the intent of the REACH directive.

4. Exclusions

This warranty is limited to replacement of the parts sold. No other costs may apply. G.L. Huyett makes no warranty as to fitness or merchantability of its parts for a purpose or particular use. For additional information see the G.L. Huyett Terms of Sale.

To submit questions or for clarification of this important policy statement.