This document is updated on a quarterly basis. Revisions are highlighted in red.
A positive answer to each question indicates that you are on schedule with the REACH and CLP requirements. If a question is unclear to you or you want help, don’t hesitate to contact essenscia. Essenscia does not only support her members but has also projects to help downstream users and consultants with REACH en CLP.
For more information, please contact Tine Cattoor, tel. 0496/59 36 15, tc@essenscia.be.
The first registration deadline for phase-in substances has passed.
- Check supplier safety data sheets (SDS) for the registration status of their substances. For registered substances the registration number shall be mentioned on the next revision.
- The list of registered substances can be consulted on the ECHA website. (echa.europa.eu/registered/registered-sub.aspx). Please note that substances
o may be exempt from registration;
o may not need to be registered yet; or
o may have been registered but the information of the dossier is not yet dissiminated.
- Review your REACH inventory. Are you manufacturing/importing new substances since your last update ? Did you stop manufacturing/importing ? Did volumes increase/decrease ? It is recommended to update your inventory on a quarterly basis to assure that you remain compliant with the registration obligations. Phase-in substances that you produce or import for the first time can still be preregistered until 1 year prior to their registration deadline.
- If you produce/import a substance with a 2010 deadline for the first time, you must register before starting the production or import.
- Prepare for the next registration deadline on June 2013:
o Register as soon as possible the substances already registered by other SIEF members during the first 2010 registration wave.
o Start the SIEF discussion now.
The first extended safety data sheets (ext-SDS) are being distributed. When you receive an ext-SDS carefully review the document.
- Are your uses covered ? If a use is not covered you can
o ask you supplier to update the CSR and ext-SDS,
o make your own CSR, or
o buy from another supplier who supports your use.
- Do you have the same operational conditions (OC) as described in the exposure scenarios (ES) ? Are all risk management measures in place ? You may need to use scaling to prove that you are working within the safety bounderies of the ES. Note that you have 12 months to comply to a safe use as described in the ES.
- Document your assessment of the ext-SDS.
Authorisation
- The annex XIV includes now for the first time six substances which are subject to authorization.In case you are using one of these substances, check carefully with your supplier whether he will apply for an authorization for your use or whether you will have to prepare an authorization dossier.
- In case you are using one of the annex XIV substances, consider evaluating alternatives and developing a substitution plan.
General
- Include the REACH process in your standard business processes (R&D, purchasing, marketing, training, …). Product Safety Management should be part of your existing management system.
- Do you check the presence of candidate list substances in imported and manufactured articles and do you communicate concentrations above 0,1% (w/w) to your customers ? Don’t forget that Belgium considers it to apply to parts of an article if the part can be sold separately.
- Prepare for the 1 June 2011 candidate list substance notification deadline. Producers and importers of articles must notify ECHA of candidate list substances present in their articles over 0,1% (w/w) and the total volume of the substance exceeding 1 ton/year. Exemptions apply for substances already registered for that use in the article or exposure to humans and environment is excluded during the use and disposal of the article.
New substances added on the candidate list have to be submitted within 6 months after the inclusion.
Current candidate list contains 46 substances. Check the ECHA website for the latest list. http://echa.europa.eu/chem_data/authorisation_process/candidate_list_table_en.asp
- Do you check compliance with the restrictions of annex XVII ?
- Are you ready for an inspection by the Authorities ? Inspections have started !
Essenscia developed a self assessment tool to check compliance with the REACH regulation. All articles for which you can be penalized in Belgium including the level of the penalization are listed in the tool. The tool is available for members on the essenscia extranet.
Get ready for CLP
- Are your SDSs compliant with the new format of Regulation 453/2010 (revised Annex II of REACH) ? A transition period of 2 years (until 1/12/2012) may be applicable. For substances both DSD and CLP classification must be included on the SDS.
Essenscia developed an overview document when a new SDS format is applicable. The document is available for members on the essenscia extranet.
- Do you have a transition plan in place for the mixtures that you are putting on the market ? For mixtures the deadline for CLP classification and labeling is 1 June 2015.
- For substances requiring registration the classification and labeling should have been agreed in the SIEF before 1/12/2010 independent of the volume.
- Have you notified the CLP classification and labeling of your substances that you manufacture or import to the ECHA (starting 1 December 2010 within 1 month of manufacturing/importing). This obligation applies for all substances placed on the market that must be registered and also for hazardous substances on their own or leading to the classification of the mixture as hazardous. Do you have a system in place to assure that you notify new substances within a month of their first manufacturing or import?
- In case you are a manufacturer or importer of substances as such, have you switched to the CLP classification and labeling (obligation since 1 December 2010) ?
- In case you are a formulator, check the new classifications of your ingredients. Due to additional data available since the registration, the classification of substances might have changed. This might have an impact on the classification on your mixtures. Carefully check the SDS for more information.
- Are your employees trained on the new CLP classification and labelling ?
- Are you monitoring the new harmonized C&L proposals ? (see Registry of Intention on the ECHA website)
- Due to the classification according to CLP, the classification of the substances that you purchase, might have changed. This may have an impact on e.g. the PPE for your employees and storage conditions. Carefully check the SDS for more information.
- Some CLP classification rules and harmonized classification & labeling have been changed with the 2nd ATP (Verordening 286/2011). Check potential impact on your products.
Essenscia developed a manual to define classification and labeling of your substances and mixtures. The tool provides a summary of all the applicable rules in a condense spreadsheet and is available for members on the essenscia extranet.