Solvay established a worldwide management process in order to fulfill its REACH obligations.
A structured organizational chart , defined by the Solvay REACH Board defines the roles and responsibilities of the specialists and experts in the many fields covered : legal, communication, government and public affairs, health, safety and environment, purchasing network, IT and communication services.
Which steps have already been completed?
By 1 December 2008 the Solvay group successfully pre-registered 666 dossiers representing a total of 400 substances.
Using our “REACH Information Statement” (RIS) searching tool, it is easy to find information related to Pre-Registration status and registration intention about manufactured/imported substances.
What is at stake?
From now on, substances subject to the REACH regulation need to be registered in order to be produced or to access 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 workload. Solvay is involved in several SIEFs and consortia.
Exchange of information to complete registration dossiers within SIEFs and consortia:
Manufacturers and importers of the same phase-in substances are required to work closely together in order to share their data and to complete the registration requirements in due time. This cooperation will happen within the Substance Information Exchange Forums (SIEFs) and consortia.
The joint ECHA and CEFIC “the clock is ticking – form your SIEF” campaign intends to raise awareness on the urgent need to form SIEFs and work actively in order to meet the first substance registration deadline of 30 November 2010. A Solvay action plan directed towards businesses has been developed to give more weight to its commitment within the SIEFs.
Supply chain communication
The supply chain communication process relating to products/substances’ applications is a critical step among all REACH obligations. The uses of chemical substances have to be documented in the registration dossier and the uses of dangerous chemical substances as well as “Persistent, Bioaccumulative and Toxic (PBT) or “very Persistent and very Bioaccumulative (vPvB) require a risk assessment.
This obligation will generate very complex information flows that require an appropriate workflow process to exchange data as well as to organize record keeping and traceability.
The first main challenge is to collect the information on all applications and conditions of use of our products and to transform them into a reasonable number of exposure scenarios to be included in the Chemical Safety Reports. The second one is to transmit our own uses of the raw materiel supplied in order to register properly of our uses.
Within Solvay, a workflow process will organize the data exchange as well as the record keeping and traceability of the exchanged information :
communication of the information with the suppliers to ensure that Solvay “identified uses” will be part of the registration,
gathering of information on the uses of its products by customers and downstream users,
decision to support or not the “identified use” of its downstream users .
All these steps need to be followed in order to have a valid registration dossier and thus to ensure business continuity as well as a good collaboration between all the actors involved in the supply chain.
