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November 30, 2015

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Time to act on REACH

Companies are being urged to act now and register substances before the third and final REACH deadline. Susanne Baker explains why.

May 2018 seems a long way off. Companies that will have to register substances before the third and final REACH registration deadline might think that they have ample time to assess their portfolio and go through the process, but this may be more time consuming than it first appears.

Downstream users need to also start to assess potential supply risks. Work on Registration 2018 needs to begin now.

The 2018 REACH deadline applies to substances manufactured or imported into Europe annually in volumes between 1 and 100 tonnes.

The registration process itself is the responsibility of those manufacturing or importing substances into the EU. These companies need to work with other companies who are also registering the same substance (in groups known as Substance Information Exchange Forums – SIEFs).

If a substance is being newly registered, the process can take a long time to complete and can incur significant costs, particularly if additional chemical testing is required. Costs will be less, however, for substances manufactured or imported between 1-10 tonnes per year, as you need to submit less information.

From start to finish the preparation of registration dossier could take up to 20 months for substances in the 1-10 tonnes band (Annex VII requirements) and 32 months for a substance manufactured or imported between 10-100 tonnes (Annex VII and VIII requirements). The tests to assess the characteristics of a substance typically take between five and seven months.

In the past the costs of gathering the data required to develop registration dossiers have been shared among companies in SIEFs. But the European Chemicals Agency (ECHA) is expecting SIEFs to be smaller than they were previously because there will be more speciality chemicals. Consequently, while that should make it easier to negotiate SIEF terms and conditions, it will also mean costs will be shared among fewer companies.

Hard choices

ECHA is currently forecasting that over 70,000 registrations need to be submitted covering approximately 25,000 substances ahead of the 2018 deadline – nearly three times as many dossiers as under the first deadline in 2010.

As well as expecting a significant jump in the number of substances to be registered, ECHA is also expecting considerably smaller and medium-sized companies to be involved in the process, compared to previous deadlines.

This may create additional risks – SMEs are less likely to have internal expertise in areas such as testing strategies and dossier preparation, they may not have a large budget for external support or to put all the substances in their portfolio through the registration process. Internal resources to manage dossier preparation and to keep information updated may be stretched.

In truth, at this stage there is a great deal of uncertainty. There is still quite a large number of companies, large and small, that haven’t decided whether they will fully register the substances they pre-registered back in 2008, whether to remain just below the 1 tonne per year registration threshold to avoid registration wherever possible, or whether to drop products completely from their portfolios, either because the cost of registration exceeds the substances’ market value or because they don’t have the resources to register all of their portfolio and will focus their efforts.

Supply chain risks

As a result, we are expecting uncertainty in the market. Downstream chemicals users will also need to plan for the potential of broken supply chains and consider what would happen if they were no longer able to access formations or niches substances that are important to their business.

This is not a hypothetical risk. There are already detecting signals from the market that companies that have begun to assess their portfolios might not register some of their substances.

A survey that EEF conducted last year found that a third of companies were aware of suppliers who would be withdrawing substances as a result of the registration requirements. This increased to nearly two thirds for companies from the chemicals sector.

While this does not necessarily mean that substances will be ‘orphaned’ – not registered and therefore unable to be used in Europe – it does signal significant changes in the market that companies will need to ready themselves for. For example, the number of suppliers may drop with supply consolidated among a few companies.

Preparation essential

If you are a potential registrant and are delaying or procrastinating over registration, you need to start working now. Consider which chemicals you will register. A significant first hurdle is to ensure that you have correctly identified your substances. In the past, expensive mistakes have been made when companies have left it too late to profile their substances properly.

Next you will need to survey SIEF activity. Is a SIEF already up and running with a lead dossier? If that is the case, then one of your first tasks will be to get an estimate on a letter of access. If a SIEF is not up and running, then you need to seriously think about whether you need to, and have the capacity to, act as a lead registrant.

Armed with this information you can begin to understand the potential costs involved and make an informed decision on whether and what to register, or not.

If you do decide to register, you should also be alert to warnings from testing laboratories of potential overloads and capacity issues. It may prove difficult to book analytical work in if it is left late.

Downstream users of substances need to also prepare. Assess vulnerabilities in your supply chain. Are any of your suppliers vulnerable? Start talking to them and understand their registration intentions. Are they registering and will their registration dossier cover how you use it?

You will not be able to use that substance unless the dossier does. If a substance or formulation is business critical, could you sponsor its registration – either through human resource or financial support?

Planning and preparation cannot be overstated. Companies that start now can avoid pressure, supply chain disruption and expensive mistakes later.

Help and support

The UK Chemicals Stakeholder Forum has recently published a short briefing note for companies to help explain the registration process, answer key questions and highlight resources to help them manage registration.

Download your free copy at www.gov.uk/government/groups/uk-chemicals-stakeholder-forum#publications.

To find out about some of the other elements of the REACH regulation that might have an impact on your business see www.echa.europa.eu and www.hse.gov.uk/reach.

Susanne Baker was senior climate & environment policy adviser at EEF when this article was submitted

 

Approaches to managing the risks associated Musculoskeletal disorders

In this episode of the Safety & Health Podcast, we hear from Matt Birtles, Principal Ergonomics Consultant at HSE’s Science and Research Centre, about the different approaches to managing the risks associated with Musculoskeletal disorders.

Matt, an ergonomics and human factors expert, shares his thoughts on why MSDs are important, the various prevalent rates across the UK, what you can do within your own organisation and the Risk Management process surrounding MSD’s.

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