Transcript Slide 1
Countdown to REACH Registration Majella Cosgrave and Roseleen Murphy Health & Safety Authority 21st April 2010 Overview Overview of registration Actors in the supply chain and roles SIEF participation and data sharing Getting started in IUCLID5 and REACH IT Roles and tasks of lead and member registrants Dossier generation and submission Guidance and user manuals available 2 REACH Scope Applies to actors in the supply chain: Manufacturers Importers Distributors Downstream Users Chemicals Registration Responsibility for management of risks with Manufacturer/Importer (M/I) Registration requires M/I to: Generate data on substances Use data to assess risks Develop risk management measures Submit the Registration Dossier to the European Chemicals Agency (ECHA) 4 Scope of registration Generally, substance on its own or in a preparation, or incorporated into an article, manufactured in, or imported into, the EU, at quantities greater than 1 tonne per annum, must be registered 5 Actors in the supply chain Manufacturer – manufactures a substance Importer – imports a substance into EU from outside the EU √ Both have registration duties (if substance M/I above 1 tonne per annum) Downstream user: sources substance in EU Distributor: stores and place substance on market (sources in EU) × Neither have registration duties 6 Pre-registration to Registration Pre-Registration Ran from 1st June - 1st Dec 2008 Applied to M/I substances > 1 tonne/yr System to allow for ‘staggered’ registration of ‘existing substances’ Facilitated the formation of Information Exchange Forums (SIEFs) and data sharing Completed via REACH IT 2.75m received (143,000 substances) Registration Timelines 30th November 2010 Phase-in substances M/I at > 1000t/yr & CMR> 1t/yr & R50/53 > 100 t/yr 31st May 2013 Phase-in substance M/I at > 100t/yr 31st May 2018 Phase-in substances M/I > 1t/yr Information Exchange: SIEFs Substance Information Exchange Forum Formed for each pre-registered substance with the same identity Consists of potential registrants, data holders Forum to help registrants who intend to register the same substance Facilitates data sharing and allows for agreement on classification and labelling Different roles within a SIEF……. All SIEF participants React to requests for information from other participants Provide other participants with existing studies, upon request 11 Potential registrants Request missing information from other SIEF members Identify needs for further studies Arrange to perform identified studies Agree on classification and labelling 12 Data holders Any person holding data on the substance and willing to share it Must respond to a query from potential registrant if they hold data Not entitled to request data 13 SIEF Formation Facilitator Pre-registrant could volunteer at pre-SIEF to be the SIEF formation Facilitator (SFF) Role was/is to initiate discussions Facilitates exchange of information to allow SIEF to be formed No formal recognition in REACH 14 Lead Registrant All SIEFs must elect a lead registrant Can be only one LR for a substance Not automatically given to SFF ECHA must be informed of appointment Acts with agreement of other registrants and submits the joint dossier Most likely to submit their registration before the 30 Nov 2010 deadline 15 Consortia Type of co-operation between groups of registrants to help with data sharing No requirement under REACH May have more than one consortium in the same SIEF Consortia members still have data sharing obligations with the other SIEF members 16 Data Sharing and Joint Submission One Substance One Joint Submission One SIEF One Lead Registrant 17 SIEF participation and Data sharing Article 29(3) of REACH outlines the fundamental rule for SIEF functioning: “SIEF participants shall provide other participants with existing studies, react to requests by other participants for information, collectively identify needs for further studies……and arrange for such studies to be carried out” 18 SIEF Participation and Data Sharing Purpose of SIEFs is to share data and avoid duplication of testing A SIEF is formed when companies agree substance is the same Members assess and share data and prepare common parts of JS together Requests for data related to vertebrate testing to be responded to within 1 month Financial compensation to be agreed amongst the members 19 SIEF Participation and Data Sharing Joint submission dossier must contain: Classification and labelling Robust study summaries Testing proposal (if required) If information has been reviewed by assessor Joint submission dossier may contain: Guidance on safe use Chemical safety report 20 SIEF Participation and Data Sharing Member registrant must submit separately: His identity Identity of the substance Information on manufacture and use(s) Request as to which information should not be made publicly available The lead registrant must submit the joint submission dossier first, followed by the dossiers of the other members 21 Opt-Out Opt-out of JS under certain circumstances: If disproportionately costly If would lead to disclosure of confidential business information If disagreement with LR on selection of information Must be justified and documented Higher fee (individual rather than joint) Priority for compliance check by ECHA 22 Information requirements Annexes of REACH describe the requirements Annex VI: Registrant identity Substance identity C&L Information about uses Guidance on safe use ……… 23 Information requirements Annexes VII to X Physiochemical, toxicological, ecotoxicological studies Depend on tonnage: 1-10T: Annex VII 10-100T: Annex VII + VIII 100-1000T: Annex VII + VIII + IX >1000T: Annex VII + VIII + IX + X Chemical safety report: only for >10T 24 Fulfilling information requirements 4 step process: Gather existing information Consider the information needs Identify the information gaps Generate new information or propose a testing strategy in line with REACH obligations 25 Fulfilling information requirements Gather all available information, both inhouse and publicly available: Intrinsic properties of the substance Manufacture and use Exposure Risk management measures Agree on a form of cooperation within the SIEF regarding cost sharing 26 Fulfilling information requirements Evaluate the available data and determine key study for each endpoint Prepare robust study summaries (reflect objectives, methods, results and conclusions of full study) Determine precisely the information requirements, depending on tonnage Compare information requirements and available information; data holders may hold missing information 27 Generation of new information/ testing proposal If information gap, registrants must: Generate information for Annexes VII and VIII Prepare a testing proposal for Annexes IX and X Registrant cannot proceed alone in generation of new data; one must perform study on behalf of others All who require study must contribute to cost Within 3 weeks of payment, right to receive copy of full study report 28 Right to study reports Ownership of full study report Parties who commissioned and paid for study Legitimate possession of full study report Term not defined; have a copy with right to use it Right to refer to data Mainly where owner provides ‘letter of access’ Copy of report, with no letter of access or right to use the data not sufficient (unless publicly available and not protected under copyright) 29 Key Messages Registration applies to substances M/I at greater than 1 tonne per annum One substance - one SIEF - one lead registrant - one joint submission Purpose of SIEF is to share data, avoid animal testing, prepare joint dossier Joint (lead) dossier and member dossiers Information requirements tonnage dependent Generation of data must be agreed within the SIEF 30 Dossier Submission Overview IT Tools Registration Dossier Creating your IUCLID 5 Dossier Creating a Joint Submission (LR) Joining the Joint Submission (MR) Submitting the dossier to ECHA Post submission Fees and invoicing Known issues 31 IT - Tools REACH IT Online system used by industry for the secure submission of data and dossiers on chemicals to ECHA IUCLID 5 IUCLID 5 is an IT application built to enter, store and report information on hazardous properties of chemicals 32 Create a REACH-IT account From REACH-IT main page click the “Sign up as a company” link. provide information on: • user contact details • User ID / password • upload LEOX • company size … • billing information 33 REACH IT from Pre-registration Account Creation per Legal Entity UUID number, user name and password generated Contains pre-registrations and preSIEF details Use this account for Registration Allows for the formation of SIEFs 34 IUCLID 5 IUCLID 5 is the tool for industry to fulfill their REACH requirements The only tool for preparing the dossier: IUCLID 5 Available free of charge on ECHA website Where to get IUCLID 5 Freely available on the IUCLID 5 website http://iuclid.echa.eu Current Version of IUCLID is 5.2. Only compatible with REACH IT 2.0 36 Sign -Up A unique combination of username and password is requested to be used to access the website 37 Legal Entity Object LEO A unique identifier for your legal entity All registrants required to have LEO assigned to their company in order to: Install the IUCLID 5 application Submit a registration dossier via REACH IT A Leo was created for pre-registration 38 LEO Synchronisation IUCLID 5 and REACH-IT have to have the same LEO (i.e. they need to be synchronized) One unique Legal Entity Object (LEO) REACH-IT IUCLID 5 LEO Synchronisation If you have signed-up in REACH-IT for Preregistration purposes but have not yet synchronised IUCLID 5 with REACH-IT you must: 1. 2. 3. Login on the REACH-IT webpage Download from REACH-IT the company information (LEO) Upload the LEO in your IUCLID 5 application (during installation) 40 IT Tools in summary REACH IT for data submission www.echa.europa.eu/reachit_en.asp IUCLID 5 for data gathering and dossier creation www.iuclid5/eu One Legal Entity = One LEO file Must synchronise LEO between REACH IT and IUCLID 5 Must use IUCLID version 5.2 for dossier submission Ref: ECHA Industry User Manual 1: ‘Getting started with REACH IT’ 41 The Registration Dossier A set of information submitted electronically by a registrant for a particular substance with 2 main components: A technical dossier always required(intrinsic properties of the substance) A chemical safety report (CSR) where required 42 IUCLID 5 Dossier creation To prepare a REACH registration dossier you should: 1. Complete a substance dataset Substance (data set) 2. Create from that substance dataset a Dossier 43 Roles of Lead & Member Registrants Different roles in relation to Dossier Creation EACH SIEF must appoint a Lead Registrant (LR) to submit the Joint dossier on behalf of all registrants Other SIEF members known as Member Registrants(MR) 44 Lead Registrant Dossier Creation LR gathers and prepares the technical data Selects the highest tonnage band within the Joint Submission template Creates the Joint Dossier in IUCLID 5 Allows members to join the joint submission Submits the Joint Dossier before 30th November recommended in September (includes his own Registration) Receives his Registration Number 45 LR Dossier Creation 46 Lead or Joint Dossier Joint submission dossier must contain: Classification and labelling Robust study summaries Testing proposal (if required) If information has been reviewed by assessor Technical Dossier Joint submission dossier may contain: Guidance on safe use Chemical safety report 47 Member Registrant Dossier Creation REACH Dossier templates available in IUCLID 5 dossier creation wizard http://echa.europa.e 48 u MR Dossier Requirements Member registrant must submit separately: His identity Identity of the substance Information on manufacture and use(s) Request as to which information should not be made publicly available 49 Section 1 General Information 50 Importance of substance identity Accurate Substance identity is essential; to ensure that ECHA can be confident in the chemical identity of each substance to establish whether two substances (or more) are the same to ensure data sharing and joint submission operates effectively and correctly to ensure that the substance identity is clearly defined for hazard and risk communication one substance= one SIEF=one dossier=one registration 51 Substance Identity Substance Identity IUPAC name, EINECS or ELINCS name and number, usual trade names, CAS name and number Composition: Purity, impurities and additives together with relevant identifiers and concentrations Analytical Data: Spectral and Chromatographic data Description of analytical methods used 52 Summary of Information Requirements JS LEAD registrant Dossier JS MEMBER Dossier Joint Submission Creation (Lead Registrant) Creates Joint Object in REACH IT Invites Member Registrants to join the Joint Submission Communicate the Joint Submission name to members Assigns ‘Tokens’ to member registrants This communication must be completed outside of REACH IT in secure manner Submits Dossier before 30th November 54 The Security Token Generated by REACH IT Categorised block of text Issued by the LR outside of REACH IT Currently has a validity of 30 Days If not utilised LR can re-issue 55 Joining the Joint Submission Once the LR has created the joint submission in REACH IT The MR must confirm membership using the joint submission name and the security token 56 Viewing the Joint Submissions 57 Submitting the Dossier LR may submit the lead dossier Only once the joint submission has been created A MR may submit the Member dossier Only once the joint submission has been created, Membership has been confirmed The LR has submitted the lead dossier 58 Recommendations to Lead Registrants Directors Contact Group, Industry/ ECHA liaison recommends that the LR Communicates the date they intend to submit the Lead Dossier Give the MR a ‘cut-off’ date after which they ‘freeze’ the dossier will not allow: Accepting previously identified dormant members Substance sameness discussions Operational rules discussions Sharing existing data Agreeing C&L Finalising the CSR 59 Joint Submission Summary LR creates the Joint Object in REACH IT Communicates the JS name and security tokens to MRs LR may communicate submission date and ‘Cut off’ date to MRs LR submits the Lead Dossier (at least 2 months in advance of deadline) MR confirms membership of JS MR submits member dossier before 30th November 60 Post Submission and known issues Business rules validation Technical Completeness Check Fees and Invoicing Deactivation of SIEF interest 61 Business Rules Validation Business Rules Validation automatic system check at ECHA Format e.g. wrong IUCLID 5 template used Administrative e.g wrong registration update does not provide a valid reference number Technical REACH IT cannot ‘understand’ the substance identifiers 62 Technical Completeness Check A mandatory Check carried out by ECHA to ascertain that all the necessary elements required for a registration including the fee have been provided Carried out within 3 weeks or 3 months if submitted during the last 2 months from September 2010 Where the information is incomplete ECHA sends a request for missing information and sets a deadline for submission of the complete dossier After second TCC failure a new fee will need to be paid TCC tool as IUCLID 5 plug-in check TCC of own dossier before submission 63 Fees and Invoicing Fees automatically set based on your company details Invoice will be sent to REACH IT once the dossier has been accepted for processing NOTE Only to REACH IT inbox Invoice sets a deadline One chance to extend deadline If not paid dossier is rejected 64 Invalid & unnecessary Pre-registrations Pre-registrant not Manufacturing a substance Pre-registrant not importing from outside the EU Pre-registered a preparation rather than a substance Pre-registered the wrong substance Company activity winding up Non EU supplier has appointed an Only Representative Invalid & unnecessary Pre-registrations Substance does not require a registration Non Isolated Intermediates e.g. Ozone Annex V substances e.g. by-products Articles e.g. iron bars Substance used in food/feeding stuffs Waste or recovered substances Substances in articles , without intended release Substance is not M/I >1t/yr Deactivation within the Pre-SIEF ‘Deactivate their interest’ in the preregistration Alerts the SFF or the LR to the fact Does not delete the pre-registration and can be reversed Does not negate the duties of the preregistrant for the life of the SIEF Can demonstrate their status in REACH IT Summary Post Submission Automatic Business Rules Validation TCC Check: Registrants should use Tool Fees and Invoicing automatically set May be processing delays No registration number until fees have been paid 68 Key Points Communicate widely within your SIEF Let your LR know that you intend to register this year Ensure you have a valid UUID and LEO for use of IT systems LR must ensure the data set for the substance is complete MR must ensure that member dossier is complete Sign up to the joint submission using name and token Use the TCC tool before dossier submission Pay the appropriate fee 69 Guidance and Help ECHA Technical Guidance Documents ECHA REACH IT Data submission manuals New! Guidance Fact Sheets IUCLID 5 help iuclid/eu HSA REACHright.ie [email protected] or 1890289389 IBEC reachaid.ie and [email protected] LR Webinars at http://echa.europa.eu/news/webinars_en.asp REACHright E-Bulletin Targeted communications from the helpdesk 70