- Pre-registration is over: What next?
- Rationale of the pre-registration
- New regulation on Classification and Labelling - a complete new chapter
- ECHA Rapid Response Service for last minute questions on pre-registration a great success
- The Forum of the European Chemicals Agency - Role, responsibilities and activities
- RAC prepares for restriction procedures
- New Senior Organisational Advisor and five new Heads of Unit
- Decisions "on the hoof" but steering on course
- Interview: Andreas Herdina
- Living in Helsinki: Charmaine Ajao
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Päivi Jokiniemi and Paul Trouth
Article related to: REACH
Rationale of the pre-registration
The pre-registration of phase-in substances ended on 1 December 2008 resulting in an unexpectedly high number of pre-registrations received. The aim of pre-registration is to make it possible for companies which manufacture or import the same chemicals to share and prepare data for the registration dossier.
This reduces the need for new animal testing and saves costs since not every company needs to carry out tests individually. Pre-registration also makes it easier for companies to meet their REACH obligations as it gives them more time to register. Companies which have pre-registered their phase-in Rationale of the pre-registration substances will benefi t from extended registration deadlines. These depend on the quantities of the substance involved and its hazard classifi cation. The staggered deadlines range from November 2010 to May 2018. A
company that failed to pre-register a phase-in substance by 1 December 2008 may neither import nor manufacture it after that date until it has registered the substance with the European Chemicals Agency and paid the appropriate registration fee.
Great teamwork key to success
The pre-registration phase involved several units in ECHA: REACH-IT technical teams, experts in substance identifi cation and the helpdesk which set up a Rapid Response Service. All struggled to bring the fi rst big REACH process to a happy conclusion.
Christel Musset, Director of Registrations and IT Tools, is quite proud of how REACH-IT and the teams performed in the last meters of the pre-registration race. The IT system of the new Agency performed well as it held under the pressure of 15 times more pre-registrations than expected. "The results are impressive: during the six months of the pre-registration period, more than 65 000 companies signed up in REACH-IT and submitted more than 2 600 000 preregistrations.
Almost half of the pre-registrations were submitted in the last 2 weeks of the pre-registration period," Christel Musset said happily at the end of pre-registration. Great teamwork key to success ECHA launched a back-up procedure on 1 December to ensure that all companies could pre-register before the deadline in case the REACH-IT system would not be able to cope with the load in the last day.
ECHA management and IT experts defi ned in daily meetings the strategy and the next steps as the statistics showed a huge increase in the number of pre-registrations. The REACH-IT system was able to cope with the high number of users and pre-registrations, and only a limited number of preregistrations (about 1 000 pre-registrations) were received through the back-up system. Preparations now continue for the publication of the list of pre-registered substances by 1 January 2009.
Adrenaline in the ICT operations room
With the deadline of 1 December for pre-registrations approaching, both life and work in ECHA's ICT Monitoring Centre became gradually more hectic and stressful.
In the last weeks the staff in the Centre monitored on a permanent basis the REACH-IT application: its availability, the number of users, the load of processors, database performance, the status of bulk, network capacity and more. The staff intervened where needed and unlocked queue-fi les, blocked IP addresses or tuned further the performance of the system. The experience indeed confi rms that REACHIT is a heavy and demanding system and was under extreme pressure in the last weeks of the pre-registration phase.
At the closing time of 24.00 GMT on 1 December, a total of 2 231 632 pre-registrations had arrived with 6 206 bulk registrations submitted but still to be processed. The peak day turned out to be Friday 28 November with over 4 500 concurrent users around mid-day; even on the last day of the pre-registrations we received over 17 000 logins and over 22 000 manual registrations. Offering this capacity to the user has also been a major challenge to the infrastructure colleagues; adding servers, increasing storage capacity, moving databases to ram-disks, increasing network access, adding database indexes – all this was part of a constant effort to keep up with the unexpected high demand.
Adrenaline levels increased several times in the operations room due to external access anomalies, such as over 1 million pages requested by one user in a period of two hours, or over 15 000 user registrations from one physical location - clear evidence of "Denial of Service" attacks. Colleagues kept their cool and dealt with these problems.
Together with the high and increasing number of users, the ICT help desk received peak loads of queries with 700 user tickets that had to be dealt with in the last two weeks, unblocking user accounts, de-blocking fi le uploads and giving technical advise to users. The classic 90/10 rule applied in that 10 percent of the diffi cult issues took up 90 percent of the time. Given the high pressure on the system, it was deemed necessary to have a fall-back solution in place in the eventuality that the system would not be able to cope with the high peak load.
Such a fall-back solution offered the possibility to upload data fi les through web forms and was developed with very short time delays through close cooperation between ICT and Operational colleagues – it was tested on load and functionality, tuned and deployed. It turned out that this precautionary measure was not needed but demonstrated the promptness and the capacity of the ICT team. While being aware that the initial performance of the system was sub-optimal for its needs, the joint efforts of ECHA colleagues and co-workers resulted in a high performing and stable system in the last two weeks of the pre-registration.
A good technical and experience basis has been established for future developments of REACH-IT.
Performance of REACH-IT was constantly monitored in frequent strategical meetings.
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26 February-1 March
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