REACH, the European Community regulation, provides for manufacturers and importers of chemicals to register their products in phase-in periods. The start of the third registration phase, which primarily concerns small and medium-sized enterprises (SMEs), will be in May 2013. TÜV SÜD recommends that these companies start early with the implementation of the extensive requirements.
Following expiry of the relevant period, substances not registered under REACH may no longer be placed on the European market. "However, there is still no accurate information about the potential hazards and risks of many chemical substances currently sold on the market", says Dr Dieter Reiml, REACH expert at TÜV SÜD Industrie Service GmbH. "In addition, stakeholders are not yet sufficiently aware of the fact that REACH largely shifts the responsibility for the safe handling of chemical substances from government to industry."
The objective of REACH, the EU regulation that came into effect in 2007, is to improve the protection of staff, consumers and the environment on the basis of EU-wide legislation concerning some 60,000 substances. The first registration phase, which ended in late 2010, applied to chemical substances placed on the market in large quantities. 31 May 2013 is the deadline for industry to register all substances manufactured or imported in the EU in quantities between 100 and up to 1,000 tonnes per year. "At the end of this phase, a total of almost 10,000 substances will have been registered", explains Dr Reiml. "The registration phase for the remaining smaller quantities at and above 1 tonne per year closes in mid 2018."
REACH SME (small and medium-sized enterprise) Initiative: SMEs must act
Under REACH the suppliers of hazardous substances and mixtures must submit a safety data sheet that also includes information about the use of the substance. This safety data sheet must include a chemical safety assessment and suggest risk management measures. Also important is that information is passed on reliably along the supply chain – from the manufacturer or importer to the distributor and user.
"Since REACH establishes very extensive requirements, it can involve a lot of work and time. Given this, we advise SMEs in particular to act now", says Dr Dieter Reiml. "Rational interpretation of the regulation with foresight may prove a critical advantage in competition and even make all the difference to the survival of companies, for example in cases involving incorrect registration." Questions that frequently arise for certain substances that are manufactured or imported in small quantities are whether the quantity threshold of 1 tonne per year is actually exceeded and whether the substance will still be sold on the market in 2018. On the other hand, many SMEs do not have a sufficient number of staff to intensively deal with REACH issues.
TÜV SÜD's 'SME Initiative' is a service specialising in REACH that ensures on-time, cost-efficient and successful registration of chemical substances. SMEs are generally 'co-registrants'. TÜV SÜD's experts support them with the submission of the registration dossier, relieving these companies of the need to familiarise themselves with the REACH regulation, IUCLID and REACH-IT and to maintain and update these systems. Simplifying the entire process, this enables SMEs to concentrate on their core business.
Further information is available at http://www.tuev-sued.de/plants_buildings_technical_facilities