REACH Reaching a REACH-Milestone
The closure of the initial registration period for the European Union’s REACH chemicals regulation at the end of November 2010 marked the culmination of a period of intense regulatory activity both within Shell and right across the industry.
The initial registration phase of REACH covers high production volume chemicals which account for around 4,000 chemicals across the industry, although it is expected that by 2018 some 30,000 substances will pass through the regulation.
Registrations are a significant milestone in the implementation of REACH as they require the preparation and submission of comprehensive safety dossiers for each substance, and their identified end-uses. The key elements of these dossiers are the physical properties and hazards associated with a substance and how and where they can be used safely throughout the supply chain.
“The preparation and collation of safety dossiers has been a massive task, requiring a level of industry cooperation and interaction that we have never seen before,” says David Owen, Shell Chemicals Advocacy Manager.
“REACH is the most complex piece of legislation passed in Europe and is very specific in detailing the registration requirements, but does not provide clear instructions on exactly how to go about this. It has required the European chemicals industry to come together to find a way through the regulation, and to devise the most cost effective and workable route to compliance.”
Along with other leading producers, Shell has been instrumental in helping to establish substantial infrastructure and mechanisms to allow producers to work together and find common agreement on the information included in the safety dossiers.
The bodies created to achieve this have been Substance Information Exchange Forums (SIEFs), which represent companies that register an interest in a substance or group of substances, and product group consortia, which generally consist of the main producers of specific chemicals that take on responsibility for the safety dossiers.
Owen says the registration process has been a major learning experience for the industry and led to new ways of thinking and working, at both a product and industry level. “Before consortia could even start work on collating the scientific data, ‘rules of engagement’ had to be established under which co-producers could work together effectively, manage their intellectual property and spread the cost burden.
“Working this through at the highest industry level was key to ensuring that we developed a consistent, standardised approach to the make-up and operation of product consortia.”