In the recent ECHA webinar REACH 2018: Know your portfolio and start preparing now, ECHA shared a number of short video interviews with companies about their previous experience with the REACH registration process. When being asked what would be their main advice to companies who will be registering for the first time, all interviewees responded by stressing the importance of beginning in time. “It seems to be a long time to 2018, but it takes a long time to prepare dossiers, especially for companies starting with this issue”, says Dr. Andrea Paetz, Director of Policy at Bayer. Douglas Leech, Technical Director of the Chemical Business Association UK, agrees: “My biggest advice is what’s been said here a few times: start early.”
What’s the rush?
According to the interviewees, the work is not to be underestimated. “You need to know today what your substance is, plan time for substance identification and then you need to agree in the SIEF on who is going forward with doing the relevant testing. And then the relevant testing may take some time as well”, says René Hunziker Toxicology Consultant Lead, The Dow Chemical Company.
Pro-active SIEF participation is of major importance: “The SIEF work is essential to participate in and participate early in”, according to Bjarke Kynde, Chemical specialist, Cheminova A/S. However, in order to find your co-registrants and join the right SIEF, unambiguous and correct identification of your substances is required. The first essential – and rate limiting – step therefore is that of substance identification. “You may find that actually your substance is not the same as the partners’ companies’ substance and there are two registrations”, says René Hunziker. If you are lucky, you can cover your substance with an already existing registration. If you are unlucky, as the experience of Tiina Reivonen, Specialist PSRA at Kemira Oyj, you may find out that your newly recognized substance is a non-phase-in substance. “[Registration] takes years in that case”, she says.
The time it took to complete the previous registrations is estimated by the companies to range from 3 months to 2 years. “If you are the only one registering it may take a year or two, says Jan Nylund, COO Senior Specialist, Chementors Ltd, “but if you join a joint submission it depends on how fast you can get the substance identity done”.
To gain the necessary knowledge for this process, Fabio Stratta, Technical director and REACH Manager at Faravelli Group, advices companies to start to “study the REACH regulation, the relevant guidelines, to assess the REACH IT portal, the ECHA website and so on.” Tiina Reivonen on the other hand suggests hiring a consultant if you do not have the (eco-) toxicological knowledge in-house. Jan Nylund, COO Senior Specialist at Chementors Ltd., agrees: “Mainly for small companies it is no use to learn everything yourselves, so it’s better to use people that know what they’re doing”. Douglas Leech warns that again, the time is ticking: “There are not a lot of consultants out there, there are not a lot of test houses that are geared up to do this. They are all going to get very busy. If you don’t start now you could find yourself in a few years’ time where you’re desperate to do a registration and the backup you need is just not there because there is a lack of capacity.” Whether you will request the support of a consultant or not, it is advised to take René Hunziker’s urging words to heart: “Start today, it’s at the edge of being late.”
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