The Traditional Paint Forum

In 2007 the EU introduced a new regulation “The Registration, Evaluation, Authorisation and Restriction of Chemicals Regulation” (more commonly known as REACH) which seeks to improve human health and environmental protection. It is applicable to virtually all substances (or chemicals), which are used within the EU.

(More information can be found on the website of the British Coatings Federation (BCF) at www.coatings.org.uk from where much of the detail on this article has been taken)

It requires manufacturers or importers of substances to:

• establish the health and environmental effects of the substances they manufacture or market

• assess the risks to health and to the environment of its use

• decide the risk management measures needed to ensure its use is safe

• communicate this information to each user of the substance.

The conclusions are compiled in a REGISTRATION dossier, which the Manufacturer or Importer submits to the European Chemicals Agency. Dossiers and individual substances may be EVALUATED (checked) by the Agency or member state authorities, and specific action requested. Certain types of substances are deemed to be of high concern and their future use will be subject to AUTHORISATION (approval) by member states. Finally, member states will be able to RESTRICT the use of specific substances, if it is shown that industry’s risk management measures are insufficient.

The most obvious effect is that any manufacturer or importer of any of the many raw materials that go into traditional paints will have to register them with the EU and then may have to carry out extensive (and expensive) tests to establish their health and environmental impact. Whilst for some substances this may be a fairly simple exercise, for others with a questionable health impact such as White Lead, this could turn out to be extremely time consuming and expensive. So, not surprisingly, all manufacturers are going through their inventories with a fine toothcomb and evaluating whether it is worthwhile going through the REACH process for any of their products that have a low turnover or profit margin. In many cases, the answer will be that it simply does not make financial or business sense to carry on supplying a particular material and it seems that White Lead may be one of the first and more important casualties – but not the last; who knows what other materials will suddenly become “no longer available”?

The BCF the UK’s main paint manufacturers’ trade body, recognise this and their website states:

“REACH will impact on your business in a number of ways:

• There is no guarantee that every current use of a substance will be supported by a supplier if he believes the risks cannot be controlled adequately.

• There will be fewer substances on the market in the future. Either their risks will be found to be too high to be adequately controlled or, more likely, the costs of supporting them through the REACH process will be greater than their profitability. Loss of substances may reduce the range of products you currently use, or require them to be reformulated.”

The UK’s only manufacturer of White Lead has already announced that they will be ceasing production. As the import of more than one tonne of a substance also requires compliance with REACH, looking for suppliers overseas is not an answer.

To address this, look for possible alternatives and consider the practical and philosophical implications, TPF and SPAB held a Technical day in London on the 12th of October which is commented on below. A fuller report and some of the papers from the day will be published in the next edition of Traditional Paint News due to be printed next spring.

One important aspect that emerged was the necessity important to differentiate between the vast problem of safely dealing with existing pre-1960 lead paint that is lying beneath the surfaces of our old housing stock and the possible continuing use of lead paints for specific historic projects under strictly controlled conditions.

The other is that there is a need for proper objective research into suitable alternative paint systems to replace the use of lead paints on exterior surfaces and it is hoped that suitable trials may be set up – if support and funding permits.

Traditional Paint News
Volume 2 No 4 of our Journal was printed earlier this year and covers amongst other things the papers given at our 2008 conference “Soane: Colour and Light”. If you would like a copy of this or any of the earlier editions, they are available here

Committee changes
There are a few changes to the membership of the TPF Committee. Sophie Godfraind our Treasurer has left English Heritage on maternity leave and Ingrid Wellard is leaving The National Trust at the end of her contract. We are fortunate to have three new committee members; Cathy Littlejohn, Head of Conservation at Hare & Humphries, Erica Emery, Building Surveyor for The National Trust who is based at Hughenden Manor and Cathy Power, Senior Curator at English Heritage.

Lincoln Conference 2010
The 4th International Conference on Architectural Paint Research will be held at the University of Lincoln from the 3rd – 6th August 2010. For more information go to www.cricksmith.co.uk

Please note: Each issue of SMUDGE is written, in turn, by a member of the Traditional Paint Forum, subject to the control of the Committee. The information is provided in good faith. It is not necessarily the view of other members of the Forum; it is offered only as a contribution to the ongoing debate.