1. RoHS Directive 2002/95/EC – Restriction on the use of Hazardous Substances

This European Directive comes into force on 1 July 2006 and restricts the following substances in electrical products placed on the market in the EU from this date:

Lead, Mercury, Hexavalent Chromium, PBBs (Polybromide Biphenyls), and certain PBDEs (Polybrominated Diphenyl Ethers), where these are present at a concentration of above 0.1% by weight of homogenous material.

Cadmium above a concentration of 0.01% by weight.

Our current understanding is that all Personal Protective Equipment (PPE) products are currently exempt from this RoHS implementation date under section 8 (Medical Devices) or are products specified by the military for the security of Member States.

Although we believe our products are exempt, the legislation may be extended to cover them, and it is Scott’s policy to be compliant with the RoHS restrictions on relevant hazardous substances as soon as possible. We are on target to comply with these restrictions for the majority of our products by 1 July 2006.

2. WEEE Directive 2002/96/EC – Waste Electrical and Electronic Equipment

This European Directive imposes a responsibility upon “producers” to finance the collection, recovery and recycling of waste electrical equipment in order to meet targets set by the EU and embodied in Member State legislation. A producer is an organization that performs one or more of the following in the relevant Member State:

• Manufactures and sells their own brand
• Resells under their own brand
• Imports into an EU Member State on a professional basis

There will also be some responsibility for products supplied prior to the legislation coming into force. This legislation covers many of the products that we manufacture, however, in most of the EU Member States we are not deemed to be the Producer under the definition above.

The key date for producers' financial and collection obligations commencing under the Directive was 13 August 2005. The deadline under the Directive for beginning to meet the treatment targets is 31 December 2006.

This Directive has not yet been implemented in the UK, but WEEE Regulations could be in force by the end of the year. In many EU countries the requirements for producer registration and take-back are already in force.

Scott Health & Safety has registered as a producer with the respective Environmental Agencies in the UK and Finland to comply with the requirements of this Directive. All electronic products supplied from the UK, Finland and the USA have been marked with a “crossed out wheeled bin” symbol since 13 August 2005, as required by the Directive.

The "producer" of the electronic products is defined as a manufacturer who sells under its own brand, a reseller who sells under its own brand, or someone who imports/exports to a member state. EU countries have implemented this definition in different ways and so the registration requirements and consequent obligations vary from country to country.

In the context of Scott Health & Safety products, we are the producer in the UK and Finland. In other cases you will be the "producer" as you are our distributor who imports the products into your Member State.

The following important information is relevant to you as our distributor of Scott Health & Safety products. Where legislation in force in a country applies to you:

a) - All "producers" have a responsibility to ensure that all electrical equipment supplied to users of these products is collected once it becomes waste.

b) - All "producers" have a responsibility to ensure that all electrical waste collected from users of these products is disposed of to an authorized treatment facility, and that the recycling, reuse and recovery targets for their disposal are met from 31 December 2006 (where applicable).

c) - Under the legislation there is a requirement for free "take-back" of WEEE, which allows a small-scale customer to return the old product to the producer (distributor).

d) - "Producers" will be responsible for financing, whether through a compliance scheme or individually, the collection and treatment of WEEE supplied to distributors or users after 13 August 2005. "Producers" may however agree different financial arrangements with business customers.

e) - For "historical" WEEE, supplied to distributors or users before 13 August 2005, "producers" will usually be responsible for the costs of collection and treatment where a replacement product is being supplied. If the product is not being replaced, the user is responsible. However, "producers" may agree different responsibilities with business users.

f) - We should be advising and directing all end users to dispose of electronic waste through the appropriate waste channels and not through general municipal waste.

It is important to note that the Directive is being interpreted and implemented in different ways across the EU and there is no clear understanding of how this Directive will finally be managed through the environmental agency in each country. Scott Health & Safety will be including a statement for users in all our electronic products, which will direct end users to dispose of this waste through hazardous waste schemes according to the legislation.

We will be sending you further updates on both of these Directives over the coming months as the legislation becomes clearer. In the meantime if you have any specific questions about the products that are affected please contact Scott customer services on:

UK +44 (0) 1695 711711

Finland +358 (0) 6 3244 543 / 544

For further information on our progress or for questions about our approach to WHEE & RoHs please contact Joe Slevin mailto:jslevin@tycoint.com

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