Are we ready for REACH???
"It is ridiculously bureaucratic, unbelievably costly and—arguably—a complete waste of time. What’s more, due to the unaccountable nature of the European Commission (EC), there is no chance that of reforming, let alone repealing, the Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) Regulation. Unfortunately, though, with pre-registration having started on June 1 and set to end on December 1, REACH is something that industry very much has to live with." (HCB, September 2008)
So, are we ready?
On September 30, the Industry Coordinating Group for the Canadian Environmental Protection Act (ICG CEPA) hosted a workshop on REACH as part of their conference. The workshop/conference was held at the Renaissance Toronto Airport Hotel. Several of the government speakers were no shows (there is an election on) and were replaced by industry speakers.
The REACH workshop was presented by: Ineke Bubbels, Global Manager, REACH Compliance (Belgium), and Joyce Borkhoff, Head, Regulatory Services Canada. They alternated presenting seven topics on REACH:
- Introduction on REACH
- Pre-registration and SIEF
- Only Representative under REACH
- Article under REACH
- How to protect your Confidential Business Information
- IUCLID 5
- IUCLID 5 Robust Summaries, Example: Acute Toxicity in fish
There was plenty of material presented, but there did not appear to be anything new presented (to us). Some of the information has no bearing on North American companies, as the Only Representative (OR) must do it.
The pre-registration period ends December 1, after which it will cost a company to register their substances. If a North American company does not pre-register, they will find themselves closed off from exporting to the EU.
REACH came into force on June 1 this year. North American companies wanting to do business in Europe have very little time to arrange an OR and pre-register. Once pre-registered, the company (via the OR) will become a member of a SIEF (substance information exchange forum). Here there will be an exchange of testing information as well as agreement on classification and labeling.
There are many questions that need answers, i.e. the legal status of the OR, and no answers to be had. However, that does not mean you can skate over the pre-registration.
Time is running out, what is the status of your company?
