Ease REACH Compliance

Effective documentation management is key.

By Brian Everett, itelligence

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SIEFs are perhaps the most intriguing way that REACH has impacted the chemical industry. These forums have become increasingly popular as companies seek to offset the costs of REACH registration. (Cost estimates range from €2.8 billion to €12.8 billion over the next 11 years. According to KPMG, there is a one-time cost increase of 6–20% per product.)

By sharing testing information participating companies can save themselves a great deal of effort and money versus acquiring all the necessary information individually.

Automated documentation-management systems enable companies to substantially contribute to SIEFs by keeping pertinent information easily accessible and up-to-date. Moreover, as other members share testing information, an organization can quickly update internal documents. However, in this environment, automated solutions shouldn't be construed as tools for gaining a competitive advantage. Mutual benefit and group-wide cooperation stand as the constant bywords for SIEF interaction.

REACH places a premium on internal documentation standards. This in turn creates the need for communication throughout the supply chain. With the formation of SIEFs REACH's impact broadens to encompass collaboration across disparate — even competing — companies. As the initial November 2010 deadline approaches, chemical organizations find themselves entering into a new marketplace where the ability to access information and efficiently integrate data across the entire span of the enterprise will determine success.

Take Ten Steps for Success
These pointers can make your path to successful compliance easier:

  1. Understand your organization's role in the supply chain. This is the first important thing to address in REACH compliance. For example, is your company a downstream user or the "main manufacturer" of the chemical? Downstream users typically don't face registration requirements — the main manufacturer or importer is responsible for registering the chemical.
  2. Develop a strategy on the overall registration process. REACH requires a lead registrant for any chemical subject to registration. Develop a strategy where companies within a SIEF share the responsibility (and cost) of being the lead registrant. Designate the organizations with the most information on a chemical or the highest use of it as the lead registrant. This approach will help the organization focus on minimizing the amount of information it will must develop for registration and simplify the registration effort and cost.
  3. Adapt REACH-specific data to customer's requirements. REACH will force an organization to submit and collect data for chemicals in a specific manner. However, these data may not suffice for a customer or necessarily match its exact information needs. So, manage and deliver chemical information (such as MSDS) in the form the customer wants.
  4. Leverage information available in the marketplace. Existing information systems such as EINECS (European Inventory of Existing Commercial Chemical Substances) or CAS (Chemical Abstracts Service) can provide a portion of the information required for compliance. Proper leveraging of this information will help organizations obtain data required for REACH.
  5. Align business processes and "get your house organized" prior to undergoing REACH registration. Preparing the organization for REACH registration is as important or more important than the registration process itself. Essential preliminaries include making sure the company's vision, mission and operational execution are correctly aligned and clear.
  6. Plan how data will be stored internally and used in your organization. It's essential to centralize information and ensure that every company unit requiring access can locate and update data.
  7. Evaluate the cost/benefit of the registration process. Registration fees for each substance are published and are defined upfront based on tonnage level. An organization should optimize its business/operational processes so it only pays the appropriate registration fee based on the tonnage requirements.
  8. Focus on integration of information. It's very important for a company to be able to collect purchasing and manufacturing information throughout the year so it can "prove out" usage requirements in case of an audit. Tightly integrated purchasing and manufacturing processes make that easier.
  9. Leverage use of the IUCLID-5 database. This database is the key vehicle for transmitting information to the ECHA. Construct the organization's infrastructure so information can interface directly with IUCLID-5 (if not stored there). REACH-compliant workstations can allow for proper management of information and a "single entry point" for data entry to IUCLID-5.
  10. Continually monitor and review regulation requirements. Adjustments or revisions to registration and submission of information are likely. So, establish a REACH "subject matter expert" in the organization.

Brian Everett is chemical industry solutions manager for itelligence, Cincinnati, Ohio. E-mail him at brian.everett@itelligencegroup.com.

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