© 2007 2008 2009 2010 2011 2012 REACHWise Ltd
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ECHA says: there is no time to lose for the 2013 registrations.
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REACHReady says: start the process now.
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REACHWise says: start now and we are here to support you.
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Remember the call for action from industry as well as regulators is based on comparing the prospect for 2013 with their analysis of experience with 2010 registration dossiers.
To mention a few reasons:
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for many of the high volume chemicals more information was available;
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most companies had already experience with collaborations;
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support from sector groups is not necessarily forthcoming to the same extent;
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a limited number of substances needed to be registered.
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There are an estimated 10,000-
Companies should be making enquiries about their substances with a 2013 registration; otherwise they may be missing the deadline.
Come forward and propose to lead. If you need help, REACHWise is here
ECHA and the European Commission are even organising a special workshop aimed at potential 2013 registrants.
What is so different?
Many substances will not have been through the old type regime or similar ones. Think of the EU Existing Substances Regulation, or the US High Production Volume programme or OECD HPV programme. Therefore the starting point is not solid.
Reflection
Your position about timing
· Do you think there is time enough?
· Are you not sure?
· Do you want a fresh view?
What needs to be done?
Before your go outside
· Look for other SIEFs and consortia
· Check within the SIEF
· Think about your substance – is it the same, similar or different to the others – this helps you
· Establish resource requirement: people and expertise. Include us as part of your team.
In the SIEF
· Agreement on the substance sameness: this is the basis of any dossier. Only then is it possible to establish which data exist for exposure and hazard. Also grouping and read-
· Fill data gaps where needed and possible, i.e. Annexes VII and VIII of REACH
· Prepare dossier
· Carry out the Chemical Safety Assessment and prepare the Chemical Safety Report
· Submit the dossiers for the Lead Registrant and Members of the SIEF
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Top tip |
Our offering |
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Get an experienced project manager Someone with experience of the whole process, who can help you define the overall project and milestones |
We have a massive amount of experience with different types of dossiers for the 2010 registration deadline. |
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Know your substances. Each company needs to establish the composition of its substances |
Each company needs to know the identity of its substance so that
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Understand your end- Uses need to be expressed in a specific format. Make time and communicate with your downstream users |
We have used this method in all our dossiers as well as for communication in complex supply chains for individual substances and mixtures. |
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Participate Do not wait for someone else to take the lead |
We have established well running SIEFs and consortia, right from the start. If there is no Lead Registrant, come to us and we’ll explain what is involved and how to progress your substance dossier. |
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Keep control Remember it is your dossier |
We interact with the Lead and Active members on a regular basis. Our project plan ensures you know at all times where you stand. |
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Use an appropriate communication platform Behind every dossier are real people |
We operate a tried and tested IT- |
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Communication |
We establish a communication plan to inform all members. Each communication has a clear purpose and makes it obvious what happens if the recipient does not respond. This method achieves a high response rate. |
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