The ‘new’ EU Chemicals Legislation of REACH (1907/2006) and CLP Regulation (1272/2008) is fully operational and in action. Stakeholders in Industry have worked hard to meet the first registration deadlines and related requirements in time. After meeting the first deadlines, it is time to think through how to learn the lessons so far and implement an efficient and sustainable REACH Compliance strategy for the coming years.
Your Registration dossiers as license to do business are not static but need to be maintained due to changes in data, legal requirements from changing ECHA guidelines, feedback from the supply chain. New Registration dossiers need to be created to meet your 2013 & 2018 deadlines or immediately for (new) substances manufactured / imported or substances crossing relevant volume thresholds. With more efficient project management processes and interactions with the other Registrants (“SIEF Management”) sound & sustainable Registration management needs to mature in your organization aligned to the business processes and needs.
REACH & CLP result in significant changes in the supply chain communication with a revised extended Safety Data Sheet (eSDS) & Label as main information carriers up and down the supply chain. Companies throughout Europe will have to deal with the revised eSDS of which the first will be distributed from December 2010 onwards. An important new legal requirement is that a company has 12 months to comply with the content of the eSDS, but only when it contains a registration number and/or exposure scenario (ES) attachments. This means that each company has to check whether all its own uses and known/communicated uses in the supply chain are covered; to check whether the onsite uses are safe and in line with the prescribed risk management measures in the relevant Exposure Scenarios and to process the relevant Exposure Scenario data into the companies’ product SDS’s. These Exposure Scenarios are the main new element that will have to be integrated into your company’s current SDS Management process to be REACH Compliant.
Enforcement of REACH is done by the Member State Competent Authorities (MSCA) that will inspect your local plants on REACH Compliance. So far, REACH Registration management work is often done centrally in the organization. The changed eSDSs with the REACH Compliance data will come in on the plant and need to be processed against the plant specific conditions. Are your plants ready for REACH compliance?
From the practical implementation lessons learnt at companies as LyondellBasell and others, Onno Jongerius Consult BV (specialized in strategic & practical REACH & CLP support) & Caesar Consult (specialized in the creation, evaluation & review of Chemical Safety Reports and Exposure Scenario’s) have jointly worked out a REACH Compliance Training Program. The aim of this Reach Compliance Training program is to support you to:
- Identify the relevant REACH Compliance elements and efficient implementation strategy for your Company and
- Provide practical REACH Compliance In Action training & solutions for the various stakeholders involved in new REACH Compliance matters to deal with.
The REACH Compliance Training Program is modular. These modules can be followed in sequence, but can also be attended separately. On request, the training program or selected modules, can be organized in company, with the advantage that it can be adjusted towards the company specific situation and needs.
The trainers are very knowledgeable of the legal requirements and practical implementation of REACH Compliance in companies and they are used to provide interactive working sessions with the participants. The training materials including practical support tools & formats developed will be available in English for the participants as take away to structure their own REACH Compliance processes and procedures efficiently.