CO2_2016 - page 62

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Chimica Oggi - Chemistry Today
- vol. 34(2) March/April 2016
KEYWORDS: REACH, registration deadline 2018, roadmap substances of very high concern, circular economy,
non-toxic environment.
Abstract
REACH is clearly more than the registration of substances. The interaction with evaluation and
authorisation and restriction is becoming more and more clear. The communication on these via the
ECHA website is improving constantly and new developments are reported. This will clearly not stop in 2018. REACH will play an
important role in the discussion on implementing the action plan for the circular economy, as well as in the discussions on the non-
toxic environment. On global level, REACH will contribute in achieving the sustainable development goals. The author shares his
personal view how this legislation is much more holistic than many understood end 2006. Without this holistic concept companies are
losing track what is happening with their dossiers.
Will REACH still be there after 2018?
If you had asked in Davos whether they knew REACH,
the majority might have answered yes - of course, it is an
English verb. Only those closer to the chemical industry
may know that this is a piece of European legislation on
chemicals requiring companies to register substances,
falling under the scope of registration, in 2010, 2013 and
2018, and for all new substances entering the European
market. And those who could tell you more could be
counted on the fingers of one hand.
Currently many companies are preparing the 2018
deadline registrations, and many downstream users are
interested in finding out whether the substances they
are using will be registered and whether their use will be
covered by the registrant. ECHA, together with national
helpdesks and stakeholders, is actively raising awareness of
this last registration phase. ECHA has created a dedicated
section of their website related to the 2018 registration
deadline (1).
People working daily with REACH know, however, that
REACH will be far from over after the third registration
deadline in 2018. REACH can be seen as an iceberg, and
the registration part is what you see above the water.
Below the waterline we have for instance evaluation - both
dossier and substance evaluation. They will both trigger
further activities from industry to obtain and provide the
necessary information, be it on the hazard deficiencies or
missing information on uses, tonnages and exposure. The
best in class will of course not be confronted with further
requests.
In 2013 ECHA and several stakeholder organisations,
together with some Member States’ representatives,
launched the chemical safety report/exposure scenario
roadmap. This plan for improving the content and use of
exposure scenarios, is running from 2013 until 2018. In total
21 actions were defined and are developed in five different
action areas. Work is done to increase the common
understanding, to develop new tools that are needed,
to develop IT tools and standardisation and to support
formulators and end-users. This goes from developing
a harmonised phrase catalogue for communication in
the exposure scenarios, over practical communication
on environmental release and consumer exposure up
to methods to handle mixtures and communicate in an
appropriate, understandable way to “non-chemical users
of chemicals” like hair dressers how they should handle the
products they are using in a safe way. For this activity, too,
ECHA has a dedicated section on its website (2).
In updating the dossier, industry will discover that the IT
system used for registration will be upgraded in June 2016
to IUCLID 6, and the IT system should recognise the weak
points observed in the first two registration deadlines and
will systematically close the back doors that were still
available in the previous version. This will integrate as well
the strengthening of the “One Substance, One Registration”
(OSOR) principle following the adoption by the Commission
of the Implementing Regulation on joint submission of data
and data sharing (3). It will be made technically impossible
REGULATION
ERWIN ANNYS
Cefic European Chemical Industry Council,
Avenue E. Van Nieuwenhuyse 4, B-1160 Brussels, Belgium
Erwin Annys
1...,52,53,54,55,56,57,58,59,60,61 63,64,65,66,67,68
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