Did you see this [emphasis is mine]? "Disclaimer This information is an interpretation of the Regulations (EC) No. 1907/2006 and / or (EC) No. 1272/2008 by the Federal Institute for Occupational Safety and Health. It has been drawn up with the greatest possible care and is based on sound knowledge of chemical law. The information represents the national view, which may change on consultation on a European level. Any legal recommendations, information and indications are not binding, and it is expressly the case that no legal advice is given. Any liability claims of a material or immaterial nature against the Federal Institute for Occupational Safety and Health which arise from the use or non-use of the information provided or from the use of faulty and incomplete information are hereby invariably excluded unless they are demonstrably attributable to wilful or grossly negligent action by our organisation. Any duplication, publication and propagation of the text, including in electronic form, is subject to the express permission of the German Helpdesk." -----Original Message----- From: [email protected] [mailto:[email protected]]On Behalf Of Crane, Lauren Sent: Wednesday, November 28, 2012 9:09 AM To: [email protected] Subject: Recent information from Germany on Once an Article Always an Article
Just saw an apparent German REACH CLP helpdesk position from September on the "Once an Article Always an Article" (1O5A) interpretation of articles, particularly as it relates to REACH article 33. ( link <http://www.reach-clp-helpdesk.de/de/Downloads/Kurzinfo/Kurzinfo%20Einmal%20 ein%20Erzeugnis%20-%20immer%20ein%20Erzeugnis%20engl.%20Fassung.pdf?__blob=p ublicationFile&v=5> ) Does anyone have experience with this German position being enforced? Note that the position qualifies the 1O5A a bit by introducing the idea of "removed reversibly". It seems that under this methodology an IC soldered to a PCB would not be a separate article any more, but one that is plugged in would be a separate article. Regards, Lauren Crane KLA-Tencor - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <[email protected]> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <[email protected]> Mike Cantwell <[email protected]> For policy questions, send mail to: Jim Bacher: <[email protected]> David Heald: <[email protected]>
