Precious metals REACH consortium urges firms to join
Some 30 firms have already expressed an interest in joining a consortium to prepare for registration under the REACH Regulation, the European Precious Metals Federation (EPMF) has revealed as it invites further members by a deadline of 15 September.
The key purpose of the “precious metals consortium” is to bring manufacturers, importers and downstream users to tackle tasks such as agreeing on substance identities and “sameness”, assessing hazard and risk availability and commissioning testing where necessary.
Although it is an initiative of the EPMF, the consortium will be a stand-alone body with its own secretariat and chairman to ensure separation of interests.
Under the Regulation, companies are required to share all vertebrate animal test data and incentives are provided to encourage them to share other data as far as possible under a “one substance, one registration” principle in order to maximise the efficiency of implementation.
The consortium will cover gold, silver and platinum group metals and their compounds but EPMF has deliberately not publicised specific substance lists in order to encourage companies holding data on substances that may offer read-across potential to come forward.
EPMF points out that the incentives to firms in joining its consortium include greater certainty in decision-taking and lower costs to generate registration data. At the same time it gives assurances to respect confidentiality where necessary. Members are invited from within and outside the EU.
It has taken the EPMF six months to pull together the legal and scientific resources for the consortium. Members are offered access to in-house legal, commercial, product, chemistry and eco-toxicological expertise, as well as external independent consultants.
The association has devised a cost-sharing formula that is split into:
“generic” costs covering administrative issues. These are split evenly between all members of each consortium, giving them each equal voting on such issues;
three sets of “metal-specific” costs - one for each of the metal groups - covering testing and information gathering. These are allocated according to the number of substances a company chooses to register through the consortium, and the manufacture/ import tonnage band of the substance.
Late-comers to the consortium will be charged compensation for the costs incurred by existing members in the years prior to their entry, up to a limit of ten years.
EPMF’s REACH and GHS manager Caroline Braibant said the aim is not to penalise anyone but to create an incentive for companies to join early. She said EPMF is keen to ensure that “registration dossiers to be submitted jointly are prepared as complete and on-time as possible, considering that testing institutes and experts will become very scarce in time”.
The consortium plans its first assembly in December to which only members that have joined by the deadline will be permitted. Its first priority will be to agree on substance identification decisions in time for the pre-registration period under the EU Regulation from 1 June 2008 to 1 December 2008.
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