Start Now: REACH and Joint Registrations
The cornerstone of REACH is its registration component, where companies pull together data about the properties of a substance, determine its classification, author a chemical safety report and prescribe measures to handle it safely.
Rather than every company conducting individual tests, REACH allows for joint registration. A lead registrant submits the main technical dossier. This is usually a large company that can afford the testing required and for whom the substance means a lot. However, with three years left before joint registrations are due, there will likely be smaller companies with less experience submitting the dossier.
To walk attendees at Stewardship 2015 through the ins and outs of joint registration, Beth Bidstrup, CIH, Director, H2 Compliance Inc., led the session Preparing for 2018: Unraveling the Myths of Joint Registrations.
The first thing to remember is that companies need a lead registration in place before they can submit a dossier. ECHA has set up Substance Information Exchange Fora (SIEF) to facilitate communication between companies registering a substance. If your SIEF has been inactive, now is the time to find out why, said Bidstrup.
If you’re planning on joint registering a substance, but you won’t be the lead registrant, you will have to purchase a letter or assess (LOA) from the lead registrant. Bidstrup advised that attendees confirm that their relevant uses are covered in the lead registration, along with relevant exposure scenarios and categories. “You really need to look at the fine details of that [letter],” she said. “What are you buying is what you really want to know.”
Some companies think that the lead registrant takes care of everything for them. In fact, the lead registrant only submits the SIEF’s technical dossier. You must still submit a company dossier. After paying for the LOA, REACH will confirm your membership for joint submission. Then you submit your dossier, and you’ll receive a registration number from ECHA.
The dossier that you submit will include a chemical safety assessment. Some portion of the assessment may come from the lead registrant, but it might not. “Know what it is you’re buying and that you may have to do more work than you thought when it comes to the chemical safety report,” said Bidstrup.
The costs for a joint registration depend on the hazard profile of the substance, along with the complexity of the material, number of co-registrants and amount of existing data. It can also be influenced by the size of your company and the type of dossier that you submit.
Registration takes time, so Bidstrup recommended prioritizing substances and building a roadmap. For substances that are critical to your company, start working now on registrations now.