CK’s senior consultant Vicki Walker attended the “REACH, Time to Plan” conference held in Runcorn last week on 4th June 2014. The event was hosted by Chemicals North West of which CK is a member, at The Heath Business Park in conjunction with the RSC.
The conference attracted a range of company representatives from Compliance Managers, to Senior Chemists, to Heads of R&D. The speakers offered an overview of the requirements and regulations made necessary by the legislation in the way of presentations from ECHA and HSE amongst others, as well as insight into what effect the regulations are having on SMEs (as well as some larger organisations) and how they’ve handled it so far.
Of particular interest was a continued theme of ensuring that companies need to start planning now for the next deadline in 2018, which is also likely to have an impact on resource required and staffing numbers.
Key take-home messages from the conference included the following:
- Ensure you are aware of the responsibilities of your business whether you are a supplier, a downstream user or an article manufacturer.
- REACH affects importers and manufacturers in different ways, and knowledge of your supply chain is important for knowing where you stand (particularly whether this supply chain goes outside of the EU).
- The rules surrounding monomer and polymer manufacturers can be grey – be alert to which materials you need to register.
- Even if you, as a supplier, feel that one of your products may not be as important to your portfolio as some others – consider your customers who may rely on that one product for their business ventures.
- Ensure you know the ‘sunset’ dates for any SVHC chemicals you may be using – and whether your use is included in the authorised uses. Use of these chemicals will not be permitted after the ‘sunset’ date and penalties are in place for those who do not comply. You must ensure that you have submitted an authorisation request by the ‘apply by’ date (18 months before the ‘sunset’ date) otherwise you will not be able to use the chemical.
- Start planning now –
- REACH implementation is likely to be a costly process, including but not limited to: registration fees, authorisation fees, data sharing fees, communication fees, legal/ contract fees, consultant/ recruitment fees, etc.
- You may wish to consider being Lead Registrant within your consortium unless you prefer to ‘go it alone’.
- Start thinking about your resources and whether you wish to employ a consultant, or a full time member of staff to train up in the years to come.
- For those that use contract testing facilities to analyse their products, be mindful that labs will be getting booked up the closer we get to the deadline and that they may have already started receiving bookings.
- Be aware that REACH-experienced individuals are already in short supply and that this will be a continued trend as we get closer to 2018.
If you unable to attend the conference and would like further details please click here to contact Vicki Walker