Companies should prepare for "a whole army of inspectors" descending on them to check compliance with REACH registration obligations and dossier updates in January, an Echa official has warned.
The investigations fall under the seventh REACH enforcement project (Ref-7).
Initially the focus was on full REACH registration checks, including whether substances registered as intermediates fulfil the necessary requirements – that a substance is only manufactured and used under strictly controlled conditions (under REACH Articles 17 and 18).
However Johan Nouwen, head of Echa's Support, Forum and HelpNet Secretariat, told delegates at the Chemical Watch Enforcement Summit in Brussels this week that dossier update checks were later added to the scope.
Echa’s Enforcement Forum decided to follow up on the top proposed action to emerge from the European Commission's second REACH Review – that of encouraging dossier updates, he said.
Checks will include imported chemicals, in cooperation with customs authorities in the 31 member states of the European Economic Area, all of which are expected to participate in the project.
Around 270 people from national enforcement authorities (NEA) will attend Echa's annual training event on 3-4 October, which will centre around Ref-7 inspections, Echa subsequently told Chemical Watch. Around 200 of those will be "remote" participants.
Those inspectors trained first will have the responsibility of training others at national level, and "multiply" the impact on the training.
The total number of inspectors to be employed under Ref-7 is not yet known, but Echa said data collected at the end of 2017 showed there were close to 1,000 trained as a result of its annual training for trainers.
Ref-7 will run for one year and will be followed by a report at the end of 2020.
In his address, Dr Nouwen also outlined the enforcement Forum's upcoming five-year work programme, which he said was "nearly ready."
Key areas of focus during the period between 2019-2023 will include:
- control of imports through close cooperation with customs authorities;
- internet sales of chemicals; and
- improved cooperation between NEAs in cross-border cases, which, Dr Nouwen said, is "critical in enforcement along the supply chain".
Regarding REACH registration obligations, "the duty will never be over and will now become routine part of all checks", Dr Nouwen said, adding risk management measures will "now form the focus" of REACH enforcement.
The Forum is also working on the REACH Review actions. These include a recommendation to enhance enforcement (Action 13) and removal of overlaps in REACH and the Occupational Safety and Health (OSH) legislation interface (Action 12).
As part of Action 13, Echa's Forum and member states are requested to establish comparable parameters on enforcement and report activities annually to Echa.
Dr Nouwen said the Forum is still discussing how to address this, but an active proposal will explore what information would be useful for the Forum and NEAs and will test-run an annual report.
Improved cooperation between REACH and OSH is one of the Forum's priorities, Dr Nouwen said. It will conduct a survey within member states to find out inspectors' existing divisions of roles, cooperation practices and training needs.
On CLP, the Forum will explore the enforcement of new requirements on the notification of data on hazardous mixtures to national appointed poison centres, Dr Nouwen said.