With 2013 registration deadline fast approaching, companies are busy preparing for the 31st of May 2013 registration deadline for phase-in substances greater than 100 tons per year.
What will distinguish those registrants that are successful and those that are struggling to organize their registration and met the tight timeline – Project Management.
So you know you have to submit a registration in 2013 for your substance but feel lost as to what to do next. In order to successfully register your substance(s) you will need to navigate within the SIEF, pull together existing company data, identify and fill information gaps, and prepare a registration dossier. One of the most challenging requirements may be assembling your chemical safety report with relevant exposure scenarios, including your own uses, as well as gathering your downstream user’s (DU) uses. Your job increases with complexity when you have to manage multiple substances with differencing requirements and issues. Experience shows that no one substance or registration is ever the same or as smooth sailing as you hope. If you have not done a registration before you might be thinking, where do I start?
So you should take a deep breath, grab a big cup of coffee or tea and then begin to assess what needs to be done, by when, what is your supply chain, what information do you have, and what is missing. Consider whether you have the expertise and resources to manage such a project, considering timelines and the significance to your business.
You need to consider that a 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.
A successful Project Managers use Project Management tools and processes to ensure that at a major and minor task level, parties fully understand the scope, deliverables, risks, assumptions, flexibility and timeline/resources for delivering services. A Program Manager should be appointed that has ultimate accountability for aligning the various project requirements on deadlines and to oversee that any individual Project Contributors are delivering the actual services. It is important to adopt Key Performance Indicators to ensure that, at any point in time, there is visibility of the status of the project and program, as well as indicators where there is a risk of missing key deadlines. Primary communication across the project team ensures that all stakeholders are aligned and updated. It also provides an opportunity to share Best Practices and Lessons Learned from each aspect of the program.
As REACH dossiers have several layers of data requirements and are driven in a sequential nature, development of a communications model and plan should be considered. Routine communication should occur between the project technical team and the key technical representative(s). Consider the following communication plans as a minimum, with the frequency driven by the length and level of the registration being completed, initial kick-off sessions, technical review sessions every two to four weeks in the early and mid-term phase of the project, and sessions weekly or bi-weekly (as required) in the last several weeks. The project team should establishes an agenda and coordinate the sessions. In between there should be less formal one on one communication between project members to address more specific issues. A collaborative project within an IT environment EF Leadshould be considered for complex or higher volume dossiers with access provided to the “SIEF leadership team only”. The IT system should be available over the internet, to ensure that all members have access to the latest status on any project or task. This should be the primary Project Management Tool that creates a collaborative and organized project environment and allows for successful project management, archiving, cost reporting, communication, etc.
Build your 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, which enables the H2 Compliance Team and partners to expertly project manage our services. It is also used to provide accountability for any work we complete for our clients.
If you would like to outsource your REACH registration projects H2 compliance would be happy to help, contact us today.
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