J. Allcock & Sons Ltd
Incorporating Wellington Rubber Co Ltd
+44 (0)161 223 7181
Recycling scrap rubber into reusuable material
Tel: 0161 223 7181 Fax: 0161 223 0173
RUBBER CRUMB COMPLIANCE.
From the onset of the regulations, we liaised with the UK Competent Authority i.e. the H.S.E. to ascertain our commitment under the new regulations. It was suggested that we pre-register all the ingredients contained in a generic, tyre tread formulation.
The "generic" tag was required because, obviously, the tyre producers were not going to give us access to their carefully guarded, secret formulations.
We pre-registered all the ingredients via the Helsinki portal, and received an immediate response from Helsinki direct – "Surely the materials you have pre-registered are the components of a mixture that will produce an article, and so are not liable for registration". This was the response we expected.
The situation is that the original ingredients, not the mixture, are regulated. Even the polymers (rubbers) are not regulated, but their monomers are.
If the basic raw materials are regulated, the mixtures and articles made from them must be.
Our position is that the waste stream material we use, has originated from tyres, or the tyre carcass, made by, either national or multinational companies, whose basic, bought in, raw materials will already have been subject to the REACH regulations, via their suppliers, before they are incorporated in the tyre material
Even the small independent re-treaders will use bought in tread compound, or pre-cured tread sections, where the same situation will apply.
Our process recycles the materials by size reduction only. No chemical additions are made. Therefore all our grades of Tyre Tread (TT) crumb and granules etc, are REACH compliant.
(The above statement is aimed at tyre tread materials. Within limits, it will also apply to all types of rubber crumb)
Dated: June 2014.
A J Rushton (Managing Director)
N L Challinor (QR)
J. ALLCOCK & SONS LTD
J. Allcock & Sons Ltd Registration Number 228726
Wellington Rubber Company Ltd Registration Number 332331
|Description||Technical Data Sheet||Safety Data Sheet|
|Rubber Crumb REACH Statement||Downloadable version of the Rubber Crumb REACH Statement|