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We bridge the gap between manufacturers of
raw materials and customers in Europe.

REACH is well under way. But as with all vehicles without comparable predecessors, also REACH meets some start up problems. Which is not surprising when you realize how many parties are dealing with REACH and that all those different stakeholders are assigned to work it out together. And REACH is not a closed system; it interacts with the GHS, CLP (fully operational by June1, 2015) and how we set up our safety data sheets.

This month all substances with yearly volumes of 100-1000 tons need to be registered. The next dead line is on May 31, 2018, for substances with a yearly volume of 1-100 tons. That is the target. The practical problems are especially valid for the SME (small and medium sized enterprises):

  • 700 substances are still without lead registrants. When ECHA (the organisation supervising the REACH process) investigated this fact, they found 600 monopoly positions; dominant manufacturers, shrouded in silence, awaiting the dead lines for registration, after which they will become the only parties allowed to offer these substances. The competitors are seemingly too small, too divided and badly informed. The remaining 100 substances proved to be registered already under different names;
  • ECHA still keeps possibly dangerous substances on a candidate list; meanwhile it stays uncertain whether these substances will still be available and if yes, under which conditions? Entire industries are awaiting decisions;
  • Manufacturers are not nearly fully open about their products. Neither do they always disclose whether they consider their products to be dangerous (‘substances of very high concern’). This is the ancient struggle between conscience and personal gain, but also between different viewpoints;
  • Re-use of substances and articles is made more difficult, because every recycler must maintain an authorisation file for every dangerous substance that could be found in recycled plastics, glass, metals, paper, etc;
  • Safety datas heets are becoming real book works; 25 pages are no exception anymore. The communication on safety data sheets, if possible, account for even more paper; due to the long chain of stakeholders and users the sheets are becoming increasingly more complex until they are practically unusable. At a calamity, nobody opens an encyclopaedia to find out how to act;
  • How the rules are maintained is not equal in all EU countries; comparable companies in different countries are controlled in very different ways;

One objective is evidently reached by ECHA: the European Union entered into a broad discussion on chemical substances. Next goal: to let the larger parties share and to give the smaller parties a voice, because the real power is still with those who hold the most information. And a little sense of reality in Helsinki.

 

The Sirius Effect

Last March 26 ECHA organised a stakeholders day. 300 attendants joined and another 1635 listened online. This kind of initiatives helps to bring all interested parties together and hopefully in alignment in the future. Sirius voted along with the SME and adds an important extra point to above bottle necks; the costs for the SME w.r.t. REACH are disproportionally high. The subsidy which the Dutch SME receive from the Ministry for Iinfrastructure and Environment, through the trade organisations, helps to some degree. Just like the decrease of registration fees which ECHA is considering for the European SME’s. The highest costs however are left undisturbed; the letters of access, the drafting of safety sheets and –reports, the administration and the external advisors and experts; they place a disproportionally high pressure on the small and medium enterprises. Sirius keeps track of these developments and thus defends the part of the supply chain where you manage your business.

In 2013 you not only choose for the right raw materials but also for the relevant information.

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