ECHA advises lead registrants on SIEF management issues
The European Chemicals Agency (ECHA) has published a set of recommendations for lead registrants based on advice from the Directors’ Contact Group (CW 13 April 2010). It has also issued a list of substances it expects to be registered by the first REACH deadline of 30 November.
The advice to lead registrants aims to help them manage input from Substance Information Exchange Fora (SIEFs) and submit their REACH registration dossiers on time.
According to ECHA the DCG recommends that lead registrants tell all SIEF members the date at which they intend to submit the lead dossier and provide a cut-off-date after which the following activities will stop:
- Accepting previously dormant members
- Discussing substance sameness
- Discussing operational rules
- Identifying data gaps
- Sharing existing data
- Agreeing classification and labelling
- Finalising the Chemical Safety Report, if done collectively
The agency says lead registrants are responsible for setting the cut off date, but also have an obligation to ensure that all SIEF members have enough time to provide studies and information. The DCG recommends that lead registrants set a cut off date for any of the above activities at around two months before the planned submission date. Any information generated after the cut-off date can be included in an update of the dossier after it has been registered.
The DCG also notes that lead registrants are also responsible for setting the costs of sharing information in a fair, transparent and non-discriminatory way.
The agency recognises that lead registrants and SIEF members are interdependent and cooperation among SIEFs is essential for successful registration; yet that cooperation - sometimes between many players, on complex issues - is challenging.
Meanwhile, ECHA has also published a list of the chemical substances that companies say they plan to register for the 2010 REACH deadline. It says the list - of 4,415 substances - is not exhaustive, but based on recent survey results.
The agency says downstream users should consult the list to make sure the substances that need to be registered by 30 November this year - namely high volume and hazardous substances – are included. It will be illegal to manufacture or sell these substances within the EU after that date if they are not registered. Manufacturers and importers should also consult the list, says ECHA, to ensure substances they plan to register are included.
If substances are missing, the agency advises downstream users to contact their suppliers and enquire about their intention to register; and inform ECHA about the substance, including EC number and name, via a form on the agency’s website. Manufacturers, importers or Only Representatives can similarly inform the agency of their intention to register “missing” substances. ECHA will periodically publish an update of the list.
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