Top Ten Most Commonly Asked Questions about REACH Compliance

The five top questions about REACH were addressed in detail in a recent story published by the Product Stewardship targeted outlet Environmental Leader. Featured story was on the front page and was authored by our own Russell McCann.

Environmental Leader takes on REACH regulation

Click here to view entire article. Specifically, the Environmental Leader article tackles:

What is the REACH time-line? Graphic time line included, reprinted here with permission.
What is the goal of REACH? Goal: the safe use of chemicals.
What is the difference between an SVHC list and a SIN list? Chemicals on the SIN list will likely end up on the SVHC list (more on SIN vs SVHC lists).
Will there be REACH-like chemical regulation in the U.S.? Yes.
How can a company comply with REACH and REACH-like chemical regulation? There is only one cost-effective way to compliance: database-driven REACH software, see an example here. Forget binders, spreadsheets, correspondence collections, and home-spun data-tables. It's simply not good enough.

Chris Jellen's Supply Chain Data Management blog on REACH

The Supply Chain Data Management blog has compiled :

What is REACH? REACH stands for...
Who can I contact with questions on REACH? Helpdesks or U.S.-based experts...
Does REACH apply to substances (solo, in mixtures, or in articles) manufactured or imported in volumes below 1 tonne per year? Yes, sometimes...
Do substances at nano-scale fall under the scope of REACH? Yes, but...
Who has to register substances? It's complicated...
Do I have to register alloys? REACH documentation refers to alloys as "special mixtures" or chemical cocktails. This means an alloy is to be treated the same as other mixtures under REACH. Specifically, the alloy is not subject to registration, but the alloying elements (e.g. metals), irrespectively of the alloy production process, are subject to registration.
Can downstream users continue to use a substance, if it has not been registered or pre-registered? Yes.
Are any substances already subject to authorization? Not yet, but...

Click here to view the complete article: questions about REACH.

REACHspot

REACHspot is a long-running blog that recently answered the following question:

What happens behind the scenes in the next two months at ECHA? Regarding the November 30, 2010 deadline for REACH Registration:

"For dossiers arriving after 30 September 2010, there will be a 'floating' period -- about six months of uncertainty -- regarding the status of REACH registration. What will happen is: ECHA examines the dossier on arrival, and, if the dossier is not complete, ECHA writes to the registrant before 1 March 2011. Companies will then get a reasonable deadline (typically a further four months) to provide the information requested by ECHA. If the information is not provided satisfactorily, then registration has failed, and there is no second chance.

"Failed means: the company does not receive a registration number and the substance cannot legally be manufactured or imported in the European Union – worse, any manufacturing or import since the registration deadline will have been illegal."

Interesting behind-the-scenes peek.

ECHA: REACH frequently asked questions

ECHA's Frequently Asked Questions (often referred to as "FAQs") contain questions and answers on issues "of general interest for the stakeholders," says the summary. The FAQs are compiled on the basis of questions received by the ECHA and the national helpdesks in the Member States. It can be a little bit all-over-the-place, but if you haven't found what you're curious about in this blog so far, please either contact the host of this blog -- and/or check out this FAQ:

ECHA Questions and Answers: http://echa.europa.eu/reach/reach_faq_en.asp

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