Solvay has established a worldwide management process in order to fulfill the REACH obligations for all the products and their applications and for all the activities relating to production, import, purchase from third parties, marketing and use.
To ensure the successful implementation of REACH within the Group, many different people are involved not only to cover the “geographical” dimension of the legislation but also the different expertise and knowledge needed.
A structured organizational chart, defined by the Solvay REACH Board, is in place which defines roles and responsibilities for our internal specialists and experts: such as legal, communication, government and public affairs, health, safety and environment, purchasing network, IT and communication services.
REACH phases within Solvay
1. the Pre-registration phase of REACH :
By December 1st 2008 the Solvay group had successfully pre-registered 666 dossiers representing a total of 400 substances.
2.The Registration phase of REACH :
Substances subject to the REACH regulation need to be registered in order to be produced or to access to the market before the end of the transitional period, which expires in 2010, 2013 or 2018, depending on the nature of the substances and the quantities involved.
The preparation of the registration dossiers will require a high technical expertise and a very intensive and workload.
Exchange of information to complete registration dossiers: SIEFs and consortia
The REACH Regulation requires for manufacturers and importers of the same substance to work closely together in order to share their data and complete the registration requirements in due time. This will reduce testing on vertebrate animals and reduce costs. This cooperation will happen within the Substance Information Exchange Forums (SIEFs). These are foreseen by the Regulation itself. In parallel, consortia among industrial interested parties are constituted within professional federations in order to organize data exchanges in accordance with competition law, confidential issues and intellectual property rights.
Solvay is really worried about the difficulties encountered by the members of the SIEFs: lack of commitment of SIEF members and weakness of the IT tools.The Group supports the awareness-raising campaign launched by ECHA and CEFIC “the clock is ticking – form your SIEF now”. A Solvay action plan towards businesses has been developped. All the means and the efforts are put together to reach the registration 2010 deadline.
3. The Evaluation phase of REACH
The European Chemicals Agency (ECHA) is in charge of checking the completeness of all registration dossiers and their compliance with the REACH obligations. ECHA is also co-ordinating the whole process.
As a consequence of the evaluation, the authorities could require additional information, harmonize classification and labeling and - if necessary - implement measures for risk reduction.
4. The Authorization phase of REACH
Some substances, because of their particularly hazardous intrinsic properties (Carcinogens, Mutagens and Substances that are Toxic to Reproduction), and any other substance that may create an equivalent level of concern (according to the Regulation itself) will be classified as being “Substance of very High Concern – SVHC”). These substances will be subjected to a process of Authorization that will lead to either a ban or a restricted use.
