REACH 2018 - Do you have a plan yet?
Chemical Companies prepare for REACH 2018 Deadline
12 January 2016
The 1st June 2018 deadline for REACH registrations is approaching and hopefully you already have work plans in place for those substances you intend to register. If not, I recommend you move, fast!
According to the European Chemicals Agency (ECHA);
"It is expected that up to 70 000 registrations will be prepared for 2018. This is three times more than previously prepared for either of the previous deadlines."
Based on my past experience, the workloads encountered by analytical laboratories, contract toxicology and eco-toxicology test houses, consultants and the registrants themselves were high for the 2010 and 2013 deadlines and with up to three times more registrations expected for 2018, industry can expect to be overloaded.
A lack of testing capacity for generating analytical data or poor availability of consultants who you may rely on for compiling your dossier, (because they're busy creating and submitting dossiers for other Companies), could lead to you not submitting your dossier in time.
This type of non-compliance with the REACH regulation means you would have to remove your substance from the EU market for a period resulting in financial costs to your business and damage to your reputation with your customers.
I see a simple solution to avoid this. You need to plan well ahead and where possible, start the work early. I would recommend:
- Ensure you know what substances you need to register;
- Find out what data you need to generate for each substance;
- Identify what resources are needed to do the work and check its availability;
- If you need external support, identify who can help;
- Find out how long it takes to generate the required data and compile a dossier;
- Calculate how much you expect the overall costs to be for each substance;
- Inform your management of the above so you can secure a budget for the work over the next two and a half years.
You should expect that availability of external resource will run out the closer we get to the deadline and the cost of such resources could easily go up as demand increases.
If you leave it too late to start your work, you simply won't have time to get everything done. Consider that if you have 36 individual substances to register and you work on just 1 substance per month, you will only just complete everything before the 2018 deadline!
I would advise this sort of "little and often" approach to the work as it will help you to spread both your efforts and your costs out over the available time.
- Do not underestimate the time it takes to organise and complete testing.
- Do not assume the help you may need will be available at short notice.
- Do not assume that everything will go smoothly!
ECHA published their "REACH 2018 Roadmap" in January 2015, isn't it time you had your own roadmap in place, before it's too late?
Today’s expert blogger is Richard White, Regulatory Specialist within Intertek’s Health and Environmental Regulatory Services Group. As a REACH project manager, he specialises in the development of Chemical Safety Assessments (CSA) and Reports (CSR), IUCLID dossier preparation, validation and submission along with other related areas of work such as Safety Data Sheets and the Transport of Dangerous Goods regulations.