With 2012 well underway, the 31st of May 2013 registration deadline for phase-in substances greater than 100 tons per year is fast approaching!!
So you have pre-registered, what’s next?
As a manufacturer or importer you cannot afford to sit back any longer as there is just a little over 1 year left to register your 2013 phase-in substance(s). Of course, if you have more than one substance then your workload will increase accordingly. In order to successfully register your substance(s) you will need to navigate within the SIEF, pull together existing testing data, fill data gaps, and prepare a registration dossier.
As with 2010 dossiers, the most challenging requirement may be assembling your chemical safety report with relevant exposure scenarios, including your own uses, as well as gathering any of your downstream user’s (DU) uses. If you have not done a registration before you might be thinking, where do I start?
Any registration project should be underpinned by a strong project management oversight, which defines the scope and strategy of the project, manages the timelines and costs, and includes strong communication channels. In the end your project management system should ensure that your registration dossier is done on time and within budget, yet flexible enough to handle unexpected set-backs in your timeline. Delays are almost a guarantee when dealing with SIEFS and contract research organizations when filling data gaps and there can also be delays with your own in house resources.
Build your 2013 registration strategy and project plan with realistic and accountable tasks, phased milestones, frequent budget updates and simple reporting mechanisms. This can be accomplished with a good IT program, such as H2 Compliance’s element1, but even the best program management system cannot overcome lack of time,
So don’t delay any longer and start your 2013 dossiers today
If you would like to outsource your REACH registration projects H2 compliance would be happy to help, Contact Us today.