Reach: The Best Way to Succeed in a SIEF

As REACHReady’s Technical Manager, I get to hear all about how people are working to implement REACH, the issues they are facing and how they are dealing with them. Through this blog I’m going to share with you what I think about all things REACH-y and give you the inside track on issues as they develop, as well as suggesting a few ways you might overcome them.  One of the great things about my role is that I get to hear opinions of those affected by REACH in so many walks of working life.  I’d like to know what you think so please let me know if you agree or disagree with what I say and please share your own experiences – others might benefit from your efforts too!

One of the most common (although perhaps not popular!) topics I’m asked about at the moment is SIEF formation.  Many companies throughout Europe are trying their best to get started on this next stage of REACH, just as ECHA begins in earnest to upgrade and maintain the (hopefully!) successfully-improved REACH-IT portal.

Just as I feared last December, many if not most companies have focused solely upon getting their pre-registrations in on time and weren’t even sure whether pre-registration placed them in a SIEF, a pre-SIEF or a consortium (it’s a pre-SIEF by the way), let alone knowing what they really need to do to get their substance registered.  In fact, just a month ago – a few weeks after REACH-IT re-opened after its Christmas holidays – ECHA issued a News Alert to clarify pre-SIEFs and SIEFs (http://echa.europa.eu/doc/reachit/sief_key_principles.pdf).  It’s good to see that ECHA has realised that it’s all been pretty confusing and is trying to help. 

Industry being left to work out SIEFs by itself has prompted an influx of pre-SIEF questionnaires (some with very tight deadlines for response) and invitations to join consortia into many a “REACH@companynamehere.com” inbox. Some SIEFs have thousands of potential participants, and chemical manufacturers, importers, data holders, consultants, third parties, Only Representatives and even some REACH “spectators” have been jostling for position. This activity has come out of the blue to many and I speak to a lot of people who are very worried and who aren’t sure what to do. Perhaps inevitably, there are already power struggles developing between large, small, assertive (perhaps aggressive), submissive, enthusiastic and less-willing pre-SIEF participants.

The key piece of advice I would give right now is to know your rights: all potential registrants are regarded as equal when it comes to taking the lead in SIEF formation, and nobody can claim this position as a right.  But somebody needs volunteer to take that lead, and for that at least some credit is due.

Cultural background, personality and business practice all affect how we work with other people.  Most SIEF members won’t be involved in REACH for fun: they share the common goal of submitting a registration with the least pain possible.  For me, REACH is about people – protecting people and their environment (after all, that’s the point of assessing, registering and controlling the chemicals on the EU market!) and people working together to deliver REACH Registration.  Cooperating with our neighbours in the SIEF is perhaps our best way forward.  Even if the reasons are not completely altruistic...  After all, who knows when we might need to call on those same people again.  In my view, and I know my colleagues at REACHReady agree, it’s collaboration that will be the key to REACH’s success.