November 2, 2010 by Becky Marks
As the 2010 REACH registration deadline approaches attention is beginning to turn towards requirements from 2011 onwards.
The first thing that it is important to remember is that for substances that do not require REACH registration until 2013 or even 2018, CLP notification will still need to be carried out by January 2011! But don’t panic if you haven’t started thinking about this yet. Contact your SIEF to see if a classification proposal has been agreed, or see the ECHA guidance on CLP notification
The next REACH registration deadline is May 2013.This will apply to substances produced or imported into the EU at ≥100 tonnes per year per manufacturer or importer. These registrations will bring a new set of challenges and the deadline is only a couple of years away.
An even greater number of substances are expected to be registered in 2013 than in 2010. The total data requirements for ≥100 tonne substances are less than for the ≥1000 tonne substances. However, as this registration deadline covers less widely used substances it is likely that fewer data will be available to fulfil the REACH endpoints. This may mean there is increased use of alternative methods for filling data gaps, with more read-across and increased use of Quantitative Structure Activity Relationships (QSARs), but that some new testing may also be required.
In addition to substances requiring registration after 2010, the end of the year will not be the end of the process for those substances already registered. Following the 2010 registration deadline evaluation of the submitted dossiers will begin. ECHA will carry out a technical and scientific compliance check and will evaluate testing proposals. Substance evaluation will be carried out by Member State Competent Authorities, to assess whether the substance will cause harm to human health or the environment. Companies will need to be prepared to defend their dossiers to ECHA or the Member State, if required. This could mean justifying read-across strategies and testing proposals. Updates to registration dossiers may also be needed in the light of any new information. With a revision of the guidance on Strictly Controlled Conditionsdue, many intermediates that did not previously require a full submission dossier may need to be updated if they no longer meet the requirements for strictly controlled conditions.
At wca we have a wealth of experience in all aspects of REACH, gained from many successful REACH projects. We have been involved in over 100 dossiers that have been successfully submitted to ECHA in 2010.
• Literature searches
• Data gap analysis and development of test strategies
• Data review
• Preparation of IUCLID dossiers
• PBT/vPvB assessment
• PNEC and DNEL derivation
• Classification and labelling
• Exposure assessments
• CSR preparation
• Strategic advice on cost-effective approaches to Registration
We have worked with companies and consortia from the industrial organics and metals industries on both REACH registrations and CLP notifications and can offer advice and support to companies with 2013 deadlines, or to companies which require technical assistance to respond to questions from ECHA on 2010 submissions. We are also working with colleagues from ECHA’s Risk Assessment Committee and Socioeconomic Analysis Committee to develop practical ways of analysing Registration and Authorisation dossiers.