Are YOU Ready to REACh?

Manufacturers and marketers of chemicals in Europe who are racing to meet the November 30 pre-registration deadline for REACh seek managers with new skills to help with compliance. The Registration, Evaluation, Authorization and Restriction of Chemical Substances law requires registration of all commercially sold chemical substances with the European Chemicals Agency. The aim is to identify and monitor chemicals and, where dangerous chemicals have been identified, to substitute safer alternatives. A key feature of the new regulation is that the burden of proof that a chemical substance is safe to use is transferred to industry; the regulation it replaces left the burden of such proof with regulators.

Companies working to comply with REACh may require managers to develop new skills in Marketing, Toxicology, IT and Sourcing.

• Sourcing: “Every sourcing decision-maker will need to know whether the substance they are purchasing is registered in Europe,” said James Romine, Vice President, Regulatory Affairs at E. I. du Pont de Nemours. “Switching vendors will not work if the substance is not approved.”
  
• Marketing and sales: On the selling side, marketing managers must be intimate enough with customers to know what they are using the products for so that substitutions can be made if required. Some customers may be reluctant to part with information they consider proprietary.


• Information Technology: “For many companies, there is a massive task in organizing the substance level information in preparation for their submissions to the European Chemicals Agency,” noted Reg Norton, Vice President, Environment, Health and Safety at PPG Industries. “Submissions to the European Chemicals Agency are electronic so strong IT support is helpful to catalog the chemical substances that comprise your raw materials or products.”


• Toxicology: Toxicologists may be in short supply in the next few years. In an effort to minimize duplicative testing, the new law requires that companies share the results of testing for hazardous materials, toxicity and animal tests. However, they will need to agree how to share this information and decide who pays in Substance Information Exchange Forums (SIEFs). Additional testing work appears inevitable. Companies may have to engage outside consultants to help with the workload.

While REACh’s immediate impact is in the EU, REACh has implications for manufacturers beyond Europe. US manufacturers who sell globally will not be able to sell their products in Europe unless the component substances are registered. Also the REACh law may be used as a model for new regulation in other countries like, for example, China. It is important that the individuals managing the REACH compliance process have experience and a global viewpoint since data you generate for one set of regulations may be applicable elsewhere.

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