in this issue
Reach: Stuck SIEFs - is History Repeating Itself?
3:27 AM MDT | September 26, 2011 | By LISA ALLEN
by Lisa Allen, ReachReady, an affiliate of the Chemical Industries Association (London)
Successful REACH registration is something that is now under many a company’s belt. However, achieving it was often quite a challenge, not least getting started in good time to meet the deadline. That isn’t meant in any way as a criticism: it was groundbreaking new territory! The process was new, industry and the authorities were learning, and systems and working practices were developing based on fast-growing experience – plenty of good reasons why a project might falter in its early days.
I can hardly believe it’s more than two years since I wrote about pre-SIEFs being stuck in the doldrums, time passing with slow progress being made to establish Substance Information Exchange Forums (SIEFs) and get them moving in the right direction. But here we are again, less than two years to go until the next registration deadline, and REACHReady is hearing all too familiar stories of no activity in the pre-SIEF, few (if any) responses to surveys of intent to register, companies unsure how best to proceed in this very earliest of steps towards registration. All of this comes long before potential registrants can consider substance identity or the best analytical testing to prove sameness – possibly the next bottleneck with test houses bound to reach capacity as demand rises.
For substances already registered in 2010, pre-SIEF members with a 2013 deadline should ideally make contact with the relevant REACH consortium, Lead Registrant or SIEF leadership team. In most cases they will be able to obtain guidelines for proving substances sameness, a pre-requisite of joint submission, and purchase a Letter of Access to the information they require for their tonnage band. Sounds simple enough..?
Think then of the pre-registrants of substances still unregistered across the EU: those substances not manufactured or imported at 1000 tonnes or more per year and those without particular high-hazard classifications. Where no SIEF, consortium or Lead Registrant exists these companies are starting from scratch, much like those involved in the 2010 registration deadline. Someone needs to take the lead, and find the balance between the urgency to drive the SIEF forward and the need for fairness, transparency and non-discriminatory action. As we saw in the first phase of registration, doing so isn’t easy.
The good news is that the wheel has already been invented. New SIEFs should benefit from the experiences – good and bad – gained by industry in that first registration phase. So much has been learned about how best to operate the SIEFs during the run up to the 2010 deadline, and how good and inclusive communication is critical to this process. It also helps that there are now a range of options and tools available to help potential Lead Registrants and SIEF leadership teams manage the delivery of a joint registration and in managing the communication within the SIEF.
NOW is the time for companies to start taking action if they need to register in 2013. It’s not too late to stop history repeating itself, but to make the next deadline we do need to get those SIEFs moving!