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REACH and ECHA communications – reminder for the vacation season

August 29th, 2017

REACH registrants, particularly those in a Lead Registrant role, would be well advised to consider their arrangements during the summer holiday period to ensure any incoming emails from ECHA will not be overlooked.

Contrary to the expectations of some companies, REACH work is not ‘complete’ for a company once the initial registration has been accepted. ECHA expects registrants to maintain a registration after submission – and is actively undertaking review of registration data sets and CSRs, to ensure that a high standard of quality has been used in registration work.

ECHA makes use of automated checking methods and since 2016 has also introduced a programme of ‘manual checking’, looking more closely at various areas of data set. Submitting a registration update can attract these ‘manual checks’ but ECHA has announced that these types of checks are also being made on existing registration data sets, not associated with updating activity. ECHA’s compliance checking and other evaluation programs are continuing according to their schedule.

Consequently, all registrants should continue to be alert for incoming communications from ECHA.

In the event that ECHA identifies a need for further testing or other information, the normal process is that a draft Decision is received first, detailing the requirements. At this stage, the requirements can be discussed informally with ECHA and registrants have a right to make a written response, within a short time limit, which will be taken into account. It may also be possible for registrants to arrange to submit a voluntary update which may be taken into account. In some cases, it might even be possible that the matter can be closed at that stage. This period – normally only 4 working weeks – is thus a very important opportunity to plan and consider all available options and propose a course of action to address the perceived deficiency in the registration data set. Taking action during this period could potentially save considerable work and money later.

If this opportunity is not taken when the Decision is still at the draft stage – for example, if a draft Decision letter is not picked up until after the commenting period closes – the Decision is likely to be finalised and a statutory deadline is imposed. At this point registrants are obliged to take action to improve the relevant aspects of the registration dossier on time, and there is no longer a chance for informal discussion with ECHA. As in the original registration, the Lead Registrant will normally have responsibilities on behalf of follow-on registrants.

In some cases the required extra information may include expensive or long-running lab studies, or a complex consultation exercise concerning the uses and exposure. If other SIEF members / joint registrants are affected, it will be important to discuss with them early on, particularly if they will be expected to contribute financially to the further work.

Communications parameters change for a range of reasons – if your email address or domain changes, or if a nominated contact goes on leave or has a change of role, this important responsibility should not be overlooked.