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 support for your REACH and CLP implementation, don’t hesitate to contact essenscia. Essenscia does not only help her members with REACH and CLP but has also projects to help downstream users and consultants.
For more information how essenscia can support you, please contact Aysel Karademir, tel. 02/238 98 65, akarademir@essenscia.be.
- SIEF Agreements and SIEF work for 2010 registrations :
o Is the SIEF Formation Facilitator/Lead Registrant known ? For SIEFs without Lead Registrant, essenscia recommends to inform your supply chain timely on potential discontinuity of the supply of the substance.
o Has the substance sameness check been completed and is the chemical identification profile of your substance covered by the SIEF ?
o Is the data gap known ?
o Have the cost sharing rules been defined ?
o Will the joint submission dossier be ready in time ?
o Have you started the individual part of your registration dossier ?
o Can agreements be signed in due time?
o Can payments be made within 2 weeks? Check with your financial department.
Essenscia recommends to follow closely the SIEFs and add the current status of the SIEF to your REACH Inventory: status on Lead Registrant, substance identification, agreement, progression joint registration dossier, C&L discussion, ….
- Are you using the latest version of IUCLID 5 ? Current IUCLID 5.1 version will be replaced by IUCLID 5.2 early 2010. For the latest status, see the website iuclid.echa.europa.eu
- Do you have substances that may be classified as “dangerous to the environment” or as CMR ?
Pay attention to unknown classification due to lack of data, especially for the category “dangerous for the environment (N, R50/53)”. The registration deadline may move up to earlier deadline if found out that the substance should be classified as N, R50/53. This is also possible for CMR properties defined by self classification.
- Have you defined your communication strategy for the uses of your substances ?
o If you are a downstream user : Have you mapped the uses for all purchased substances and decided if and when communication is needed with your supplier or DU ? Do you answer additional information requests of the supplier?
o If you are a manufacturer/importer : Have you prepared a detailed overview of the known uses and exposure scenarios and decided if communication is needed with your downstream users ?
Verify with the SIEF if the CSA/CSR will be part of the joint dossier and if your uses will be covered. Check with your sector federation if common exposure scenarios are being developed.
Essenscia recommends to inform your customers about your actions, timing and expectations towards them.
- Secure that the OR will register your imported substances. Do you have evidence of this on file ?
Try to communicate directly with the OR, not only with your supplier. The OR needs the actual list of imported quantities. Communicate the actual imported tonnage of 2009 to the OR.
- In case you act as OR for a non‐EU company : Are contracts in place clearly defining your role en responsibilities ?
- Do you have a system to keep your REACH Inventory (substances, tonnage, role, …) up‐to‐date ?
Update the inventory with the 2009 quanities. Does this change any of your REACH obligations (e.g. registration deadline)?
- Include the REACH process in your standard business processes (procedure, training evidence, document control, …). Product Safety Management should become part of your existing management system.
- 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 on the esssenscia extranet.
- Did you check the presence of candidate list substances in imported and manufactured articles and did you communicate concentrations above 0,1% (w/w) to your customers ? Don’t forget that Belgium considers the 0,1%(w/w) limit per homogenous part.
- Did you include packaging materials in your inventory and checked REACH obligations for those materials ?
- Are you monitoring the new SVHC ?
o 29 substances are included in the candidate list (14 substances added on January 2010).
o 7 substances are listed for inclusion on the authorization list (Annex XIV).
o Today no substances are listed on the authorization list (Annex XIV).
- Will all your SDSs be compliant with the REACH format by 1/12/2010 ? Don’t forget that SDSs for substances must have the CLP classification and labeling by that date. The current annex II (SDS format) of REACH will soon be revised.
- Get ready for CLP :
o Classification and labeling (according to the Dangerous Substance Directive or CLP) should be agreed in the SIEF before 1/12/2010 independent of the volume. Remember that, as manufacturer/importer of a substance you will have to notify the classification and labeling of the substance to the ECHA by end 2010.
• Substances with later registration deadline – Are you following up how the SIEF is approaching this ? Do you want to become involved ?
• Substances without registration requirements – Is there a SIEF for these substances and do you want to participate in the SIEFs ?
o Are you training your employees on the new classification and labeling ?
Essenscia is offering CLP training including refundable training for people on the floor. Check essenscia’s REACH Portal in the section ‘REACH en CLP opleidingen’.
o Did you define the potential impact of CLP on your business together with your logistics, supply chain, purchasing, IT, … departments ?
o Have you reviewed the impact of the first ATP to the CLP regulation ? Implementation of this ATP is due 1 December 2010.
o Are you monitoring the new C&L proposals?
Essenscia developed a tool 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 on the essenscia extranet.