Despite the positive figures for the activity generated by REACH, one can wonder if this is an evolution rather than a revolution.
REACH IN A FEW FIGURES
Within five years, more than 27,600 dossiers have been submitted to ECHA and 5,500 substances have been registered. 14 substances are currently subject to authorisation (Annex XIV of REACH) and 84 are on the Candidate List. Before the 31 May 2013 deadline more than 2,600 additional substances are expected to be registered and ECHA should evaluate 90 substances between 2012 and 2014.
Some important data published by ECHA at the beginning of June 2012 must be added to this list: more than 40 % of the substances classified as carcinogenic, mutagenic and toxic for reproduction (CMRs) were neither registered under REACH nor notified under CLP.
2012 AND FUTURE DEADLINES ARE CAUSING INCREASING CONCERN AMONG SMES, SMIS AND DOWNSTREAM USERS
Although the 2010 deadline mainly concerned large groups (production and/or import of substances superior to 1,000 t/year), the following ones are causing increasing concern among SMEs and SMIs throughout the supply chain.
The tonnage bands decrease concerning registration: 100 to 1,000 tonnes for the 31 May 2013 deadline and from 1 to 100 tonnes for the 2018 one. Consequently, today, REACH affects an increasing number of SMEs that are often vulnerable facing extremely constraining and often costly obligations that they have not anticipated.
More and more industrials are thus concerned by REACH and their opinion on the regulation is not always positive as they hardly see the short-term advantages of its implementation, particularly concerning competitiveness.
Today, it appears to be essential for companies to integrate REACH within real global strategies linked to product compliance management, occupational health but also innovation and competitiveness.
AN EVOLUTION RATHER THAN A REVOLUTION?
REACH is evolving with the time and the market and some provisions are taking more and more importance.
One can thus note the growing importance of the Safety Data Sheets (SDS), main vehicle of all information generated by the REACH registration, allowing to guarantee risk control of the use.
Extended SDS (eSDS), with complex elaboration of exposure scenarios for substances, cause some difficulties to downstream users. Indeed, they have to verify the compliance of their substances’ uses regarding the numerous exposure scenarios they receive from their suppliers.
Article management also causes more and more difficulties to companies. They now have to communicate their composition and measures for safe use when Substances of Very High Concern (SVHC) are present above a specific concentration. This provision, almost unnoticed at the beginning, has truly been emphasised.
Lastly, the coming years will be marked by the submission of authorisation dossiers to ECHA. These dossiers will determine if a substance classified in Annex XIV of REACH is authorised to stay on the market, for which use and what period, subject to the implementation of a substitution strategy. Indeed the authorisation period is renewable only once. The complexity of the authorisation dossier emphasises the need to think REACH as an opportunity to implement global strategies within the company in order to anticipate market and regulations evolutions.
Article published in The Molecule 5
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