The second round of enforcement that focused on small and medium enterprises showed not so good compliance with REACH (including CLP):

In total, 67% of the inspected companies were non-compliant with one or more provisions of REACH or CLP. Non-compliance was most commonly related to contraventions of (pre)registration (REACH, 8%), notification (CLP, 15%), failure to keep information (20%) and having deficient risk management measures (12%).

Only 3% of companies failed to have the SDSs on site. However, 52% of the inspected SDSs showed deficiencies. Despite the high rate of defective SDSs, inspectors noticed an improvement in the formats used and availability of SDSs in comparison to earlier inspections. The findings also showed that 93% of the workers could have access to relevant information from SDSs. However, practice shows that the actual rate was, in fact, lower at 79%."

ECHA is continuing to expand its support information and webinars, but is pushing on industry to get itself into compliance with the requirements.

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