Firms must act now if they are to hit the November 2008 deadline to pre-register substance under Reach, the new European chemicals legislation, industry compliancy experts have warned.
'Reach will require a quantum leap in the resources a company requires to be compliant,' said Paul Whitehead, chairman of the RSC's Environment, Health and Safety Committee, told delegates at a Reach Readiness Workshop on 30 October.
The biggest costs associated with Reach look set to be in resources to manage the process, rather than substance testing and registration fees. 'Companies need an employee working full time on the [Reach] project,' said Nigel Marsh, head of Environmental Management at Rolls Royce Group. 'We will have 20 full time employees working on Reach by the end of 2007.'
"Reach will require a quantum leap in the resources a company requires to be compliant"
- Paul Whitehead
Illustrating the scale of the task, Hewlett Packard have estimated they will need to collect 3.5 billion pieces of data to become Reach compliant, and Rolls Royce Group will probably need far more than that, said Marsh. Jo Lloyd, technical director of advisory body REACHReady, added: 'People are starting to talk about 100 000 substances being pre-registered, rather than the 30 000 substances predicted previously.'
With the first deadline approaching, companies are being urged to prepare now for the impact of the new legislation. 'The challenge to business will be to understand Reach, and then manage the impact to maintain their market position,' said Whitehead.
From June 2008, companies have just 6 months to pre-register all the substances they make or import. Meet this deadline and you then have up to 11 years to complete full registration (exact timing depending on what tonnage band the substance falls into). But miss it and the substance will be banned from the European market until fully registered.
The purpose of pre-registration is so that the new European Health Agency in Helsinki, tasked with managing reach, can identify all users of each substance, who must then work together in a Substance Information Exchange Forum (SIEF).
'Pre-registration is free, so if in doubt about a substance, pre-register it,' said Lloyd. 'But don't just pre-register all of EINECS [the entire list of chemicals currently available in Europe], which I've heard some companies are planning to do, as then you'll get millions of emails from every SIEF,' added Tim Jessel, commercial director of REACHReady.
'Our suppliers often have a very low awareness of Reach, which is of big concern to us,' said Marsh. 'We will pre-register strategically important substances if our suppliers don't.'
Although the first deadlines are now looming large, even companies actively preparing for Reach face uncertainties over ambiguities in the legislation. Steffen Erler, a REACHReady technical manager, said, 'Substances in "articles" is one of the most notorious aspects at the moment - the draft guidelines have been removed from the Reach website. What is an article - a pen is a delivery device for an ink preparation, so does this differ from a tin of paint?'
James Mitchell Crow