Hazardous Materials, or HazMat, is a general term for Hazardous Substances & Restricted Materials (also HS&RM). In accordance with the Control of Substances Hazardous to Health Regulations 2002, a hazardous substance is defined as that which is hazardous to health. And a restricted material is any substance whereby its importing, manufacture, use, or sale is controlled by legislation.
Why is HazMat management important?
Given the potential risks associated with hazardous materials, their correct use and disposal is both a safety and environmental issue. Consequently, this is an area which continues to be scrutinised by evolving legislation.
The primary legislative mechanisms which determine the procurement and use of HazMat, fall under the Restriction, Evaluation, Authorisation and Restriction of Chemicals (UK REACH – formally EU REACH before Brexit). This, together with the regulations outlined under Restriction of Hazardous Substances (RoHS), Persistent Organic Pollutants (POPs) and Waste Electrical and Electronic Equipment (WEEE), restrict the use and importation of specific hazardous materials and determine appropriate downstream waste management processes. Failures to comply with statutory legislation may leave organisations liable to non-compliance, leading to imprisonment or financial penalties.
Within Defence, as per the Secretary of State for Defence Policy Statement, the Ministry of Defence (MoD) must comply with all applicable Health, Safety and Environmental Protection (HS&EP) legislation. In circumstances where Defence has Derogations, Exemptions or Disapplication (DEDs) from HS&EP legislation, arrangements must be maintained to demonstrate that outcomes are as good as those required by statutory legislation. This is reflected through MoD policy and regulations such as JSP 418 Leaflet 5 Management of Hazardous Substances and Restricted Materials, which defines the requirement to produce Technical Dossiers, and where non-compliance has been identified, justify any use of HazMat outside legislative thresholds.
What is UK REACH?
UK REACH retains the key principles outlines within EU REACH, setting requirements for two main aspects: 1) the provision of safety information within supply chains and 2) the formal regulation through the Authorisation and Exemption process.
UK REACH applies restrictions through the classification of substances. Of primary importance are Substances of Very High Concern (SVHC), which are identified as having significant human health and environmental implications. Alongside this, Annex XVII also defines which substances are deemed to be restricted and set specific requirements pertaining to the use, trade, import and disposal of a particular substance.
How can we help?
Safeguard Engineering offer an experienced and comprehensive understanding of Hazardous Materials & Restricted Substances. Our capabilities within our Environmental Team include the implementation of Hazardous Materials Management, production of HS&RM Technical Dossiers in accordance with JSP 418 and assurance of Hazardous Materials documentation, including IHMs. Contact us to find out more about how we can help you comply with HazMat regulations.
