ECHA has issued its 2013 review of the REACH registration process here. About 2/3 of the dossiers had issues that needed to be cleaned up. Furthermore, ECHA advises that your work on dossiers is never done - changes happen to ECHA IT systems and guidance and new risk information about a chemical can arise. Four recommendations for improvement by submitters are made in the report:
1. Keep your dossier up to date. The SIEF should be checking in with members frequently.
2. Know how to react if you get a (draft) decision. You get 30 days to respond to ECHA's claim that you have problems with a dossier.
3. Substantiate your reasoning if you adapt the standard testing regime. Read across is nice, but you better justify it.
4. The chemical safety report should reflect the actual uses and risks. Descriptions and evaluations of uses were pretty loose in the dossiers. Plus, they change all the time in the ongoing marketplace.
The report offers nice guidance on how to avoid problems.
Be aware that member countries are following up with enforcement on those who don't fix their dossiers.
- Tags:
- REACH