The EU chemicals regulation REACH entered into force already on 1 June 2007. Many obligations have since become effective or are gradually being implemented.
Virtually all industrial companies as well as trade, are more or less affected by REACH. Special demands are placed on the companies that manufacture or import chemical materials from outside the European Economic Area. But also downstream users that manufacture from purchased materials or mixtures, for example, paints or detergents have to fulfill major obligations and thus ensure compliance.
Who is responsible?
Depending on the legal form of the company either the Board or the Managing Director is primarily responsible for the compliance with the legal requirements. But he may delegate competencies and responsibilities to function managers in the company. To avoid an organizational fault clear job descriptions and control of the implementation are prerequisites for success.
The following responsibilities in the company should be considered for REACH compliance:
- Executive board / managing director: appropriate organization, control system
- Purchasing: legal purchase of raw materials and communication with suppliers
- Production: occupational safety / environmental protection and compliance with the conditions of use
- Research and development : consideration of REACH in product development
- Sales: REACH complian marketing and communications with customers
- Safety and environment specialist advice on above features and technical implementation of REACH tasks
The concept of Prosacon to achieve REACH compliance comprises three main areas (included in the base audit programme of Prosacon):
- Organisation and Structure
- Mapping the requirements
- Verification of compliance
In the first part the responsibilities within the business for REACH compliance are considered. In addition an essential element is the review of the system for purchased materials, manufactured materials and materials put on the market as well as their categorization as substances, mixtures or articles.
Depending on the activities of the company the REACH requirements are derived that are discussed in the second part. This can be the duty to register or the creation of material safety data sheets as well as the examination of the downstream user for their own chemical safety report.
In the coming months and years authorisation will become of increased importance.
In the third part we check the actual implementation of the requirements, by reviewing the system and carrying out a sample survey. The results of the investigation are discussed together as well as potential next steps. Details about our audit system you may find >>here
Prosacon also supports you with the following implementation of your action plan. Or we optimize your processes for the implementation of REACH. At the end it's not just about making sure to be REACH compliant, but to achieve this as efficiently as possible. >> please contact us here.
- Immediate stop of manufacturing, importing or marketing your products
- Damage claims of your business partners or employees
- Fines or penalties. In Germany this can mean prison up to five years
- ECHA checks as part of the evaluation process - in collaboration with the national law enforcement agencies.
- To avoid the above mentioned consequences you can check your company by a REACH audit. We examine the compliance in the context of a due diligence.
- >>Prosacon supports you with REACH.
- Portfolio analysis
- REACH registration including IUCLID5 dossier and chemical safety report
- Authorisation with socio-economic analysis
- REACH compliance check, e.g. by performing a REACH audit
- Authorisation of your biocidal products with dossier preparation
- Scientific communication with authorities in the event of an evaluation / assessment under REACH or during submission of a biocidal product authorisation
- Chemical industry
- Paints and coating industry
- Manufacurers and importers of biocidal products
- Detergents and cleaning agents manufacturers
- Plastics manufacturing and processing industries
- Electrical industry
- Automotive industry and its suppliers
- Mechanical and plant engineering
- Import traders
- All users of substances of very high concern