Producers, importers and downstream users of chemicals affected by the EU’s new REACH chemical regime have started to group together to begin the task of identifying gaps in hazard or exposure data needed for risk assessments.
European and international trade associations for sulphuric acid, nickel, tungsten, tin, antimony oxide, precious metals and cobalt are among those who have moved to establish consortia in recent months.
Although there is no legal obligation for firms to join or create consortia, it is the default solution proposed by the European Commission. In most cases, consortia members will work together to pull together the information required in registration dossiers.
Because REACH is based on the principle of one substance, one registration, these forums will work towards the joint submission of registration dossiers for substances of mutual interest.
This is in addition to substance information exchange forums (SIEF), to which all pre-registered manufacturers and importers potentially belong. These are specifically designed to help data exchange to avoid tests being repeated unnecessarily, particularly tests on animals.
Dr Steffen Erler, technical manager for REACHReady – an advisory service set up by the Chemical Industries Association – said it was “crucial” for suppliers and downstream users to get involved in various types of consortia “as soon as possible”.
“It can prove a win-win situation for all involved. Soon enough, REACH will force companies together – even competitors,” he said. Dr Erler pointed to cost benefits that companies can achieve by streamlining work, adding that many companies may be involved in hundreds of consortia.
“This can be as simple as avoiding two or more companies dedicating skilled resources to establishing different chemical nomenclature for a substance. For the purpose of pre-registration, companies can even use shared resources and expertise for identifying substance ‘categories’ for data-sharing that extend beyond a SIEF. Currently, consortia may even be reviewing the potential for a substance or group of substances to be exempt,” he said.
While no consortium-forming guidelines have been provided by the Commission, industry will have to ensure that any consortia are compliant with EU competition law. Many consortia will be treated and financed as independent bodies, supported by their own secretariats.