Quality audit of REACH dossiers

SUBSCRIBE TO CORPORATE SOCIAL RESPONSIBILITY (CSR)

Over 20,000 chemicals have been registered with ECHA since REACH entered into force, creating a database on chemicals, their uses and behavior that is unparalleled in the world. This work can be found in the Global Responsible Care Charter, for which the framework relating to Corporate Social Responsibility (CSR) was developed at the initiative of France Chimie:

1. Develop a corporate culture that proactively supports the safe management of chemicals as part of the global Responsible Care initiative.
2. Protect people and the environment by continuously improving our performance in terms of the environment, health, safety and the safety of our facilities, processes and technologies, and by promoting continuous improvement in management and safety of chemicals throughout the supply chain.

However, according to a study carried out in 2018 by the BFR (German national agency), a high rate of non-compliance was noted among the registration files submitted in 2010 and 2013 for the highest tonnages 100-1000T and> 1000T. The subject of the quality of records has become a major concern of authorities, industry agencies, but also the media and society as a whole, as with all subjects related to environmental health and ecology.

In this context, ECHA and the European Commission published on June 24, 2019 an action plan for the improvement of REACH dossiers : « REACH Evaluation Joint Action Plan - Ensuring compliance of REACH registrations ». The stated objectives are as follows:

• Speed ​​up the assessment by increasing the proportion of files verified from 5% to 20% per tonnage band (legislative act proposed in mid-2019), which corresponds to 30% of all registered substances,
• Achieve a satisfactory level of compliance of REACH dossiers,
• Regulate more substances within 9 years.

Toutefois, l'évaluation REACH est un processus complexe à gérer, dont l'issue est incertaine si les entreprises sont mal préparées et les données incomplètes.

However, REACH assessment is a complex process to manage, the outcome of which is uncertain if companies are poorly prepared and data incomplete.

ANTICIPATE REGULATIONS TO SECURE THE MARKETS AND PORTFOLIO OF SUBSTANCES

In reaction to the action plan on the quality of ECHA / CE's REACH dossiers, chemistry stakeholders through CEFIC (European Federation of Chemical Industries) encourage companies to sign a declaration of intent and to undertake to verify, and if necessary improve, their files over the period 2020-2026.

This approach allows the anticipation of the work to update the REACH registrations to be carried out, the main reasons for which we have presented in our dedicated article. REACH operates on a "no data, no market" principle. This is why good compliance makes it possible to secure your business and ensure the long-term use of your substances or even a substitution for less dangerous substances if necessary. It is also an opportunity for the regulatory affairs manager to strengthen the confidence of workers, salespeople and managers as well as that of customers.

Updating your REACH registration dossiers is essential to guarantee the safe use of substances, but also to gain peace of mind with regard to regulatory changes and emerging markets. Our team of expert chemists, toxicologists and eco-toxicologists have been practicing the REACH regulation for more than 10 years, constantly looking for an innovative and tailor-made solution to best support our customers. 

ASSESS THE QUALITY OF RECORDS BY REQUIRING EXPERTS FOR AN INNOVATIVE AND COMPREHENSIVE AUDIT

Article 11.8 of REACH provides that the REACH registration dossier may contain "an indication of that of the submitted information which has been examined by an assessor chosen by the manufacturer or the importer and having appropriate experience". Despite the authorities' interest in this type of assessment, and the IUCLID software making it possible to provide this indication, this opportunity is never seized by the companies that register.

ATOUT CHIMIE has therefore set up an innovative file audit methodology, in terms of strategic, administrative and financial as well as technical aspects. We assess all the information submitted (toxicology, ecotoxicology, physico-chemistry, analyzes, uses, etc.), in order to verify that they are in line with the best recommendations and quality standards currently in force. We of course update them and resubmit if necessary.

Thus, ATOUT CHIMIE supports you in improving the quality of your REACH dossiers and helps you formalize your commitments according to the terms defined jointly by ECHA and CEFIC.