Catalyst

by Harrie Camps, Program Manager Reach/Sabic Europe

It is important to focus on the broader opportunities created by the European Union’s (EU) registration, evaluation and authorisation of chemicals (Reach) program, rather than linger on its challenges, and this is what we have been doing at Sabic. We believe that the EU chemical industry only stands to benefit from a single regulatory system for new and existing chemicals. Reach will encourage our industry to innovate, either by replacing potentially harmful substances with suitable alternatives, or by dramatically reducing the risk posed by the use of these chemicals.

Because Reach mandates that all chemical substances in the EU be comprehensively documented, knowledge and expertise regarding these substances will increase, for the benefit of society as a whole. And since the legislation also covers chemicals that are imported into the EU, Reach will have a positive impact on the wider global market.

Taking a Pragmatic Approach  

At Sabic, we fully endorse the Reach objectives. As a responsible manufacturer and importer of chemicals, we care for the health and safety of people and the environment, and compliance with Reach is merely a logical step in the process. Yet we also see Reach as a serious business topic and as such, we have been pragmatic in our approach to the new regulations. We have assembled a professional corporate Program Management Office (PMO) to centrally guide the timely delivery of high-quality dossiers for all our products. Although independent from business and Safety, Health and Environment functions, the PMO aims to cover both needs. To help our team achieve on-time registration, we recently signed a four-year strategic partnership with TNO, a highly respected scientific research institute. With the right people and processes in place, we feel we are well placed to meet the necessary goals outlined by Reach.

As with any new legislation, it is important that companies take the right approach to ensure that they are in the best position to implement the changes, minimize the impact on the business and to keep ahead of the competition. By working with a third-party, such as TNO, who have the expertise and knowledge to help shape the approach, companies can put themselves into the best possible position to react to the changes.

Sharing is the Key to Success 

To help lessen the burden of animal testing the Reach regulation mandates that all producers and importers of a chemical substance should work together by sharing toxicology data and jointly submitting dossiers. Beyond its humane spirit this requirement also offers a clear financial benefit to producers as the expense of testing can be shared among groups of substance producers.

Sabic has already joined pre-consortia groups of producers established by the European Chemical Industry Council (Cefic) through its sector groups and will be openly sharing Reach-related knowledge and best practices with others-and the sharing doesn’t need to stop there.

At conferences and via industry networks, companies have the opportunity to discuss and compare relevant work processes with each other. In addition, Sabic is committed to using other forms of communication, such as our website and newsletters to share information on the progress of the substance registration process with customers and other stakeholders alike.

But why is sharing so important? The scope of the Reach legislation is so complex–and its impact so large–that cooperation is the surest way to produce the best results. By working together, the industry and authorities will increase their knowledge and expertise regarding chemical substances, and contribute to a healthier future for our children and our planet.

Chemical firms across Europe and beyond are having to come to terms with Reach, the European Union’s recently introduced environmental legislation. Multinationals and small companies alike will be affected by the legislation. Here’s an uncut and candid detail from specialty chemicals firm DSM on how it is approaching Reach.

DSM’s input is from Environment Manager Jan Berends and DSM Board Member Jan Zuidam.

As a company involved in both fine and industrial chemicals, what are the main challenges you face in preparing for the registration phase of REACH next year?
First of all we are working on a complete inventory of all substances that are in our products, raw materials and intermediate. All these substances have to be ‘pre-registered’ before the end of 2008. Our suppliers have to register the substances they produce or import, DSM has to register the substances in our intermediates and our products. We also collect all information that we have about the relevant substances that is needed for the registration.
In 2007/2008 we will have to assure that all essential raw materials will be (pre-) registered. We will ask our suppliers. In case suppliers are not wiling or not able we will have to act ourselves (register, change of suppliers, etc.)
We are also aligning our risk assessments, because our suppliers need to know the use and exposure of the substances they deliver to DSM. REACH requires that this is mentioned in the registration.
Main challenge is to do this 100% for over 500 products and over 5000 - 10.000 raw materials and thousands of suppliers.

How will the new regulation affect your activities in practice? (i.e.: which sectors of your activities and/or products will be affected first or most heavily?)
On short term extra work as indicated above. The largest impact we now expect is on sourcing of raw materials. E.g. additives (even non-hazardous) might be no longer available on the EU market because the importer/producer does not want to take the burden of registration. However we have to explore this better and not speculate. It should be taken into account that the period for registration for smaller volumes lasts until 2015 of even 2018. So we have to see and act accordingly.

How do you see REACH as an impediment to DSM’s activities? Conversely, how do you see the regulation as an opportunity for your company?
In first instance there will be uncertainty which is not good for the business in EU. There might be some opportunities, however as long as the EU is different from other parts of the world you can argue whether this might really turn into a benefit. Replacing hazardous substances by less hazardous has been a drive already for many products already for a long time. Companies already have the ‘duty of care’ It remains a question what the added value of REACH will be.

Do you expect your company’s results to improve or deteriorate as a result of REACH? Why? Are you planning to relocate some of your activities?
We now do not expect big impact relative to the trend. Probably we can benefit to some extend from our bio-based orientation (less hazardous substances used and produced) and our long history of responsible care activities (e.g. product stewardship, quality of product information, etc.)

If you were to introduce changes to the regulation what would they be? What would make REACH work better in your view?
I would look for simplification of the registration dossiers depending on the type and the use of a substance. You don’t have to know ‘everything about everything’, but just what is relevant in the different uses. So a more risk based approach. This in fact is the approach as applied in the EOCD HPV-program. And rather than making it full proof in the EU I would spend some energy in global harmonization, since products are being produced and used worldwide.

–Alex Scott, Senior Associate Editor, Chemicalweek magazine