Compliance / Legal Information

California Proposition 65 (Prop65)

Conflict Minerals

RoHS / REACH / SVHC

Slavery / Trafficking


California Proposition 65 (Prop65)

Proposition 65 is a California law that has been in effect since 1986 to promote clean drinking water and to require businesses to provide a clear and reasonable warning before exposing individuals to consumer products containing chemicals known to the state to cause cancer, birth defects, or other reproductive harm. Proposition 65’s formal title is “The Safe Drinking Water
and Toxic Enforcement Act of 1986.” It is administered by CAL/EPA’S Office of Environmental Health Hazard Assessment (OEHHA).

 

The law requires that no person in the course of doing business knowingly and intentionally expose an individual to a chemical known to the state of California to cause cancer or reproductive toxicity without first giving a clear and reasonable warning. An official list of these 900 plus substances is published and periodically updated by OEHHA. As a courtesy to our customers the list can be accessed at http://oehha.ca.gov/prop65/prop65_list/Newlist.html.

 

Parker Steel is a distributor of metallic raw materials that are produced by other manufacturers and we are committed to providing quality products to all of our customers. Some products supplied by Parker Steel contain chemicals, identified by the state of California as a cause of cancer, birth defects or other reproductive harm. Proposition 65 does not require warning where the exposure poses no significant risk of cancer or no observable effect as set forth in law and regulations. Exposure levels are generally expressed as a daily exposure level and not as a concentration or weight % present in a product. Exposure levels are influenced by many factors, including the intended use or application for the product. While the state of California has identified so-called “safe harbor” exposure levels for some listed chemicals, there is little regulatory guidance to determine whether or when the use of a product results in exposure below those levels and thus poses no significant risk to the average user. In some cases, testing and a risk assessment may be required to establish acceptable exposure levels for certain applications and uses. Parker Steel will provide material certifications and SDS sheets upon request and label packaging accord-lying that is shipping into the State of California with the proper Prop 65 warnings. Consumer products, which can be demonstrated to have exposures less than the safe harbor level for specific chemicals, may not require labeling. Due to the presence of Prop 65 listed chemicals in certain Parker Steel products, you may have concerns about compliance with Proposition 65. If this is the case, you may wish to include a product label on products that may be delivered within California to include the following warning:

 

WARNING: This product can expose you to a chemical or chemicals such as Lead, Chromium, Cobalt & Nickel which is known to the State of California to cause cancer or birth defects or other reproductive harm.

 

For more information, go to: www.P65Warnings.ca.gov/product
Safe Drinking Water & Toxic Enforcement Act, CA Prop. 65

 

If your company intends to use Parker Steel products as a component in a product(s) sold or delivered to consumers in California, Parker Steel recommends that you take steps to determine whether the warning requirements of California’s “Prop 65” apply. Your company is solely responsible for determining whether your finished consumer product needs to be labeled in compliance with Prop 65.


Conflict Minerals

In July of 2010, the United States Congress passed legislation requiring companies to report the use of “Conflict Minerals” in the manufacture of their products. “Conflict Minerals” in this context refer to specific minerals originating from mines controlled by armed groups in the Democratic Republic of the Congo or adjoining countries. The specific metals in question are:

  • Coltan (columbite tantalite) and its derivatives (Tantalum)
  • Cassiterite and its derivatives (Tin)
  • Wolframite and its derivatives (Tungsten)
  • Gold

 

Parker Steel Company is committed to complying with this legislation and plans to comply with forthcoming regulations and will work towards making all Parker Steel’s products as “Conflict Free”.

 

The U.S. Secretary of State may designate other minerals in the future. We support these requirements to further the humanitarian goal of ending violent conflict in the Democratic Republic of the Congo (DRC) and in surrounding countries, which has been partially financed by the exploitation and trade of “conflict minerals”.

 

OUR “Conflict-Free” COMMITMENT:

  1. Support the aims and objectives of the U.S. legislation on the supply of “conflict minerals”.
  2. Do not knowingly procure specified metals that originate from facilities in the “Conflict Region” that are not certified as “conflict free”.
  3. Ensure compliance with these requirements, and ask our suppliers to undertake reasonable due diligence with their supply chains to assure that specified metals are being sourced only from:
     •  Mines and smelters outside the “Conflict Region” or
     •  Mines and smelters which have been certified by an independent
     third party as “conflict free” if sourced within the “Conflict Region”.
  4. This due diligence includes having our suppliers provide written evidence documenting that the materials supplied to Parker Steel Company, originate from outside the “Conflict Region” or if they originate from within the “Conflict Region”, that the mines or smelters be certified as “conflict free” by an independent third party. The aim is to ensure that only “conflict free” materials and are used in products that we procure.

 

If we discover the use of these minerals produced in facilities that are considered to be “non-conflict free”, in any material, parts or components we procure, we will take appropriate actions to transition product to be “conflict free”.

 


RoHS & REACH Compliance

European Environmental Legislation – RoHS 2011/65/EU / WEEE

The RoHS/WEEE Directive is a European Environmental Legislation with the intent of limiting the amount or presence of hazardous substances in electronic devices The recast Directive 2011/65/EU (RoHS) is legally valid from 03 January 2013. Amendments and additions to the Directive such as (EU) 2015/863 amending Annex II of EU-RoHS 2 & RoHS 3, Ten substances have been identified as those who’s content must be limited Per Annex II. (See link Below – Law)

 

Lead is allowed in steels up to .35% by weight 6(a) and aluminum up to .4% by weight 6(b) with copper up to 4.0% by weight 6(c).

 

With rare exception, our current products are compliant to the RoHS Directive.
Parker Steel is a distributor of raw metallic materials and as such cannot sign a blanket statement stating everything purchased from our inventory is Lead Free. If our customers request product with a higher lead content, we can supply the item, but the customer must assume responsibility for those items specified / requested. Please refer to the Material Test Report that are available upon request with all orders to verify chemical content and compliance. Substances, which are omnipresent, for example by a carryover in minute amounts, and can be detected by today’s refined analysis methods, are not covered by this statement. The ubiquitous presence of traces of undesirable substances, however, can never be fully excluded.

 

Law: http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32015L0863
Exemptions: http://ec.europa.eu/environment/waste/rohs_eee/legis_en.htm

China RoHS 2

The China RoHS 2 Directive is a derivative of the European Environmental Legislation with the intent of limiting the amount or presence of hazardous substances in electronic devices. As of 7-1-16, the six substances

 

The relevant hazardous substances are listed below:
Lead and its compound, Mercury and its compound, Cadmium and its compound, Hexavalent chromium and its compound, Polybrominated Biphenyls, Polybrominated Diphenyls Ethers.

 

With some exception, our current products are compliant to the RoHS Directive.
Parker Steel Company is a distributor of raw metallic materials and as such cannot sign a blanket statement stating everything purchased from our inventory is Lead Free. If our customers request product with a higher lead content, we can supply the item, but the customer must assume responsibility for those items specified / requested. Please refer to the Material Test Report that are available upon request with all orders to verify chemical content and compliance. Substances, which are omnipresent, for example by a carryover in minute amounts, and can be detected by today’s refined analysis methods, are not covered by this statement. The ubiquitous presence of traces of undesirable substances, however, can never be fully excluded

IPC RAQ Link: http://www.ipc.org/3.0_Industry/3.4_EHS/2016/USITO-Translation-China-RoHS.pdf

Registration, Evaluation, Authorization and Restriction of Chemical Substances (REACH)

REACH is a European Community Regulation on chemicals and their safe usage. This law went into effect back in June of 2007. The general purpose of this law is to protect humans and the environment from intrinsic chemical substances. Parker Steel Company is a distributor of metallic raw materials that are produced by other manufacturers. The components of these materials (articles as defined by this legislation) do not intend or expect any of the listed components to be released as part of the design. Consequently, such products are considered exempt from the pre-registration and registration under REACH. As a courtesy to our customers, we have included the most recent “Candidate List” Directive 76/769/EEC for substances identified by REACH (Rev. June 29th 2018). Please go to the following link for a breakdown of the substances.

https://echa.europa.eu/substances-restricted-under-reach
http://www.chemsafetypro.com/Topics/EU/REACH_annex_xvii_REACH_restricted_substance_list.html
http://echa.europa.eu/en/web/guest/candidate-list-table

Please refer to the Material Test Report that are available upon request at the time of an orders to verify chemical content and compliance. If you have any questions or concerns regarding any of this information, please feel free to contact us.

 

Parker Steel REACH Compliance Letter

 


Slavery & Trafficking

More info coming soon…

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