INSIGHT: To dare to share

14 September 2009 16:05  [Source: ICIS news]

By Nigel Davis

BRUSSELS (ICIS news)--This a challenging phase in the Reach process. The EU regulation seeks the registration of the many thousands of different chemicals sold each year and, ultimately, the sanction of their use. Reach extends the health and safety debate up and down many, many supply chains.

Companies operating in those supply chains are challenged now to understand what they are all about. “Why do we use chemical X: would it be better to look for an alternative?” is a possible valid question for some.

For those that are serious about a particular product or substance this is the time of intense debate. Time is running out to gather all the data needed to register high volume chemicals under Reach. Health and safety data need to be collected, vetted and verified. Substance registration dossiers need to be prepared.

The European Chemicals Agency (ECHA) is clearly concerned about the speed with which data are being gathered on the chemicals that will need to be registered in 2010. The number runs into many thousands.

“This is a marathon not a sprint,” the agency’s executive director Geert Dancet said on Friday. He was speaking at a meeting organised by the ECHA and the European Commission in Brussels to address the vitally important needs of the companies and organisations that will be lead registrants in the Reach process. (The lead registrant of a so-called ‘substance information exchange forum’ – SIEF – drives data collection and information exchange on the substance and submits the primary registration for that product.)

The SIEF lead registrants' role is critical and their concerns are many. No rules have been written for SIEF creation or operation. Companies and trade groups are expected  to develop the SIEF process as they go along.

The SIEFs should, however, help the gathering of more consistent data across a range of substances. SIEF best practice should eventually be developed. Experience sharing will be vitally important.

The ECHA is trying hard to make the lead registrants' role attractive. It wants to see SIEF formation accelerate towards the 2009 year end by which time it wants to monitor progress.

The ECHA can offer carrots and sticks. It revealed on Friday details of an information programme designed to assist lead registrants and, ultimately, the SIEFs themselves. This includes dedicated webinars and discussion forums and, hopefully, much more in the way of information exchange.

Companies have many gripes about Reach but the SIEFs and the lead registrant’s role are key to helping minimise the need for toxicity testing and, ultimately, the cost of Reach to industry.

Some SIEFs appear to be running well but the registration process, involving data collection and debate, is proving to be vastly more complex than some must have initially thought.

"Consistency", "openness" and "simplicity" were all words heard at the lead registrants meeting. Reach is a vast undertaking and some methods are being developed as they go along – the whole idea of the SIEF is a case in point, it was not part of the original plans.

But companies need consistency on the part of the ECHA, the European Commission and the competent authorities in the EU member states that will police the new rules. They are the ones expected to create and populate sometimes vast SIEFs.

The most forward thinking companies expect to work proactively within the rules and it is encouraging to hear that the ECHA intends, in future, to help SIEF lead registrants obtain the information they need and to create the web-based discussion forums from which best-practice can be learned.

SIEF operation has to be learned from scratch and requires dialogue. Both lead registrants and the ECHA, for instance, want to be clear about why some substance dossiers fail while others do not. The Reach registration process has turned out to be much, much more complicated than most in industry envisaged.

However, SIEF formation has to step up a gear if Reach registration is to make real progress in the early part of 2010. And lead registrants would do well to be learning by experience now.

“We wish the lead registrants to register over the summer next year,” Dancet said on Friday. To do that, they have to be up to speed soon.

To discuss issues facing the chemical industry go to ICIS connect

By: Nigel Davis
+44 20 8652 3214

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