Tempus Fugit! Time Flies! Very traditional on a grandfather clock but not good for companies dealing with the 2018 REACH registration deadline. We are more than halfway through the 5 year “wait” between the 2013 and 2018 registrations and the ECHA REACH 2018 webpage (http://echa.europa.eu/reach-2018), added in January 2016, has a countdown to keep it visible.
Tempus Fugit! Time Flies! Very traditional on a grandfather clock but not good for companies dealing with the 2018 REACH registration deadline. We are more than halfway through the 5 year “wait” between the 2013 and 2018 registrations and the ECHA REACH 2018 webpage (http://echa.europa.eu/reach-2018), added in January 2016, has a countdown to keep it visible.
While ECHA is counting days, companies need to be counting kilos. Kilos by component, that is. Counting currency has always been a part of business and counting the kilos that account for that currency is standard; REACH is requiring companies to count kilos by chemical component, which can be problematic for more complex mixtures. The challenge escalates when some components of the mixtures are both imported and domestically sourced. REACH is “straightforward” if the business only sources domestic inputs already covered by the manufacturer. Doing so is rare for most companies. Who is tracking the importer of record at the component level? What if chemical reactions are involved? Is the reaction another substance or is it a polymer where monomer tracking is required? These points must be taken into consideration when implementing a REACH solution.
Larger companies with higher volumes who participated in earlier registrations may have this covered, but the upcoming 2018 registration is only 1000 kgs per annum. This will add a large number of small-to-medium-size businesses who may not be as prepared. In the chemical industry, 1000 kilos per annum isn’t much and volumes can ramp quickly. A counting system needs to be in place no later than 1 Jan 2017 to have figures (and registrations) by May 2018 and counting as of 1 Jan 2016 would have been preferable to show year over year trend. (Please note: If tracking finds a chemical wasn’t pre-registered, companies may be able to take advantage of the late pre-registration option until 31 May 2017.) Tracking component-level data via Excel spreadsheets or Access database has proven to be time consuming and highly subject to error. Now is the time for the ERP system to “talk” to the chemical composition system in order to help the business decide what needs to be notified. For example, at UL The Wercs, our systems connection technology (called DTE) marries sales data from ERP systems, like SAP or Oracle, with component-level data within The Wercs software. Companies having taken similar compositional reporting to an automated process have stated reductions of labor days per report reduced down to minutes per report; leaving more time for other steps in the process.
ECHA’s REACH 2018 Infographic shows 7 steps from “Know Your Portfolio” to “Keep Your Registration Up-to-Date”. Once the chemicals that need to be registered are determine, one still needs to find co-registrants, get organized, assess hazard and risk, prepare the dossier and then submit the registration. The steps leading up to dossier preparation may take longer than expected. Finding co-registrants shouldn’t be an issue in theory because there are other companies that have stated their intent to register the chemical component available through ECHA. Unfortunately, some are experiencing response to initial pre-SIEF inquiries to potential co-registrants running as low as 20%. Dossier preparation may not be a concern if your business plans to join an existing dossier submission but don’t under-estimate the amount of time, and cross-functional involvement, in contacting an existing SIEF and getting documentation in place to be part of that submission to ECHA. Cost of Letters of Access and making sure all downstream uses are covered is time consuming and expensive. Several companies who have shared their registration experiences have talked about the administrative costs as much as the actual registration fees.
Planning should start with ECHA’s REACH 2018 website, (http://echa.europa.eu/reach-2018). If further assistance is required with chemical component counting, please contact us at info@thewercs.com.
By Joan McGuffey
Senior Regulatory Specialist
UL Information & Insights | The Wercs
The Wercs provides leading software automation tools and services for GHS SDS Authoring and Distribution, REACh, and Supply Chain Insights that help advance environmental health and safety around the globe.
www.thewercs.com
