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Agrochemicals | Pharmaceuticals | Biocides and Industrial Chemicals | REACH

EU Chemicals Policy (REACH)

Introduction

On 29 October 2003, the European Commission published a proposal for a review of the EU’s chemical substances policy.  The proposal overhauls the current systems and provides for a new, comprehensive system for the regulation of chemicals known as

Registration, Evaluation and Authorisation of CHemicals (REACH).

Under the new system, all chemicals manufactured or imported in the EU at levels greater than one tonne per year will need to be registered.  Chemicals that are of concern to humans or the environment may need to follow stricter evaluation or authorisation procedures.  Downstream users of these substances and manufacturers of goods using chemical substances will also be affected by this legislation.

REACH will be implemented on 1 June 2007, and from then on, manufacturers, importers, and downstream users of chemical substances will need to comply with the regulations. The first action that manufacturers and importers will need to carry out is pre-registration of their chemicals, for each intended use, between 1 June and 30 November 2008. Manufacturers and importers will then need to register their substances, in line with the deadlines for the tonnage categories into which the substances fall.

What is Exponent doing?

We are already helping our clients prepare for REACH by helping them to establish priorities, assessing how REACH will affect their business, and providing them with regulatory advice. We have worked for a number of companies including a cleaning/maintenance products manufacturer, a global chemical company and companies in the metals and agrochemicals industries. We are also involved in developing guidance documents through the REACH Implementation Process (specifically RIP 3.2-2).

What can Exponent offer you?

We are a global company, with a presence in the EU, US, and China. We offer a global perspective when acting on your behalf. The varied backgrounds of our staff scientists give us a unique perspective and understanding of both industry and government, and we have a proven ability to solve complex problems. Our strong scientific approach is combined with an in-depth understanding of industry and business, so that we offer a comprehensive package of consulting services to help you comply with the requirements of REACH.

We offer a wide range of consulting services, and provide technical and regulatory expertise, to help you comply with REACH including:

• Initial inventory - initial assessment of substance inventory and scope, data gap analysis, identification of responsibilities and obligations;
• Vulnerability analysis - identification of short, medium and long-term priorities and actions based on risk;
• Provision of regulatory advice and strategy;
• Acting as an Third Party Representative for EU companies or an Only Representative for non-EU companies;
• Pre-registration of substances;
• Negotiation and representation in the Substance Information Exchange Fora (SIEF);
• Document preparation - production of technical dossiers, Chemical Safety Assessments (CSA), Chemical Safety Reports (CSR) and Exposure Scenarios that include hazard evaluations, exposure assessments and robust human health and environmental risk assessments. Use of data waivers, surrogate data, computational modelling and (Q)SARs will help reduce time and costs;
• Input of information into IUCLID 5 and use of REACH-IT; and
• Establishment and management of Task Force and consortia.

Whatever the obligation or issue you need to address for REACH, we will work to help you meet your obligations in a cost-effective and timely manner.

If you would like to know more about REACH and your obligations under this new regulatory umbrella, please contact:

Alec Willis
Regulatory Project Manager
The Lenz, Hornbeam Business Park
Harrogate, North Yorkshire HG2 8RE, UK
+44 1423 853216 (office); 
awillis@uk.exponent.com

Angelina Duggan
Managing Scientist
420 Lexington Avenue, Suite 1740
New York, City, NY 10270, USA
+ 1 212 895 8113 (direct);
+1 212 895 8100 (office);
+1 646 660 2677 (mobile)
aduggan@exponent.com

Marie BenKinney
Senior Managing Scientist
3 Clock Tower Place, Suite 205
Maynard, MA 01754, USA
+ 1 978 461 1225 (direct);
+1 978 461 1226 (office);
+1 508 353 0670 (mobile)
benkinneym@exponent.com

We have produced a number of two page summaries on REACH and we would be happy to send you one relating to your own particular circumstances free of charge.

Further links

ECB - general information on REACH
ECB _ REACH implementation projects
HSE - UK competent authority
European Chemical Agency

REACH Ready - UK Chemical Industry Association
Exponent International
Exponent Inc.