The European Union regulation of chemicals, REACH, requires industry to document safe use of substances manufactured or imported to the EU. Many companies are now working intensively to submit pre-registrations of substances before the deadline on December 1, 2008.
Pre-registration of substances
DHI is currently assisting a large company in Germany with the necessary preparations and pre-registrations and subsequent registration of substances under REACH.
The first request of the company was to obtain assistance with an assessment of the substance portfolio with the aim of setting priorities for the future REACH activities and, thus, enabling the company to organize their internal resources. This assessment focused on identification of substance identities, estimates of annual market volumes, and identification of substances exempted from registration and possible substances of very high concern.
The current activities are mainly related to collecting the required data for pre-registration and to submit pre-registrations for a large number of substances.
Substance Information Exchange Fora
Companies who have submitted pre-registration(s) shall participate in a Substance Information Exchange Forum for each substance with the purpose to facilitate sharing of data and agree on classification and labelling. Dependent on the strategy decided by the company, the company may take either an ‘active’, ‘passive’ or ‘dormant’ role in the SIEF, where ‘dormant’ means that the company does not have the intention to register the substance.
DHI is working in close contact with the company’s regulatory affairs unit. Currently, DHI assists the company with general advice and provides resources to enable the company comply with the workload. The assistance of DHI is to be continued in 2009 and onwards, where the re-presentation in SIEFs and contributions to meet documentation requirements will require substantial resources.