ECHA

As the 2013 REACH registration deadline approaches and that of 2018 already looms on the horizon; as communicating in the supply chain has duly become a prominent topic at conferences and in discussions on implementing REACH; and as labelling obligations under the CLP Regulation are to be followed, the task of reaching out to small and medium-sized (SME) duty holders is recognised as a crucial activity for many to undertake, including ECHA. Even if the chemicals sector is characterised by a number of well-known large and multinational manufacturers, looking at the entirety of duty holders, SMEs outnumber the rest. After all, they provide the backbone of the EU economy overall.

Before entering into the subject, however, I add a caveat. Not all SMEs need special attention. Some companies that have claimed to be SMEs turned out not to be such at all. In many cases, they were small entities of a large chemical mother company. Since 2011, ECHA has been running a check on the claimed SME status of registrants and found some confusion as to companies' actual status. Of the genuine SMEs too, not all are either struggling with or too little informed of their obligations under the European chemicals management regimes. Last year, we analysed feedback from successful registrants of the 2010 REACH registration deadline. About half of all SMEs were middle-sized companies, mostly in a position to dedicate some specialised staff to handle their obligations. Another sizeable element of the SMEs consisted in fact of micro-companies, often located in the UK. These very small actors were even more adept at using ECHA's tools and documents than large chemical companies. With this in mind, we recognised that the remaining proportion composed of small companies that may need our targeted special attention was relatively small in comparison to the totality of registrants. Finally, we often hear a statement made that small companies need attention because of linguistic difficulties although nothing indicates that their staff's educational standards differ from their national averages. It is more often the complexity of REACH and CLP that appears to be a hurdle for them.

So, what is ECHA doing for SMEs?

As a starting point, one key realisation is that ECHA needs to engage intermediaries to reach out to them. There are simply too many small companies to address. The Agency has a number of platforms at its disposal to do this.

One such platform is the HelpNet: the network of national REACH and CLP helpdesks organised and chaired by ECHA. The Agency regularly provides helpdesk correspondents with information that needs to be conveyed to SMEs, trains the correspondents in the use of ECHA's IT tools so that they can advise company customers how to use them accordingly, and also involves them in specific awareness-raising campaigns, such as currently on "REACH 2013". This approach makes use of the exclusive knowledge that national helpdesks have of the structure of their domestic chemicals sector and of their established contacts with interested actors. National helpdesks are the "first port of call" for duty holders in their respective countries, and thus naturally also the first instance for guiding SMEs with regard to their obligations. Evidently, national helpdesks are also best placed to communicate with their domestic companies in the respective national language or even regional dialect – something that ECHA is neither meant nor staffed to do. National helpdesks draw on the original as well as translated version of ECHA's Guidance documents, and additionally on their own national material, to give orientations to their customer companies.

ECHA dedicated part of its latest HelpNet Steering Group meeting, held in April of this year, to sharing best practice and experience of national helpdesks in reaching out to SMEs. One realisation of this event was that the structures of national economies are very specific and require differing national approaches. The exchange of views between national helpdesk correspondents, for instance, found some significant differences even between countries with traditionally strong chamber organisations, looking more closely at the relatively centralised French structure and the sector-wise and regionally more fragmented SME picture in the Italian economy. Involving these chambers is essential to reaching out to SMEs. The French authorities, for instance, published a dedicated brochure on REACH, sent staff to speak in French regions and followed through a programme of seminars. Similarly, the structure of the involved public authorities differs from one Member State to the other, determining the usefulness of differing national practices too. Whereas a single body can reach out to companies in Malta, Germany's federal system and size makes its administration rely on help provided at Länder level, sometimes through dislocated town-hall-style meetings.

In this light, ECHA focuses on providing the umbrella for respective activities. It acts as an initiator, catalyst and promoter of campaigns – from "REACH 2013" to awareness-raising on CLP duties or soon on authorisation applications – providing content, dedicated logos and specific campaign material. Recently, for instance, ECHA launched a joint campaign together with the confederation of European trade unions (ETUC), aimed at reaching out to companies by means of their employees. ECHA has also placed emphasis on inviting SME representatives to its annual Stakeholders' Day held in May as well as the two lead registrant workshops that it is organising this year (the first happened in February, the second is to be held in autumn). These events are web-streamed so that companies can either watch them live or on the ECHA website thereafter. Readers can also profit from the numerous webinars on a wide range of subjects when they visit the ECHA website. Moreover, ECHA's specific "REACH 2013" web page will provide links to respective information on national websites, as from September. The ECHA website also contains a dedicated SME web page.

The Agency is also cooperating with other bodies, such as the European Enterprise Network (EEN), in addressing SMEs, together with the European Commission. To animate communication in the supply chain – an obligation under REACH and prerequisite for registrations to provide correct information on the actual uses of substances – ECHA, as partner in the Directors' Contact Group (DCG), is also devising promotional means in close cooperation with industry associations as well as the Commission. ECHA runs a special network, ENES – the Exchange Network on Exposure Scenarios. This network and the CSA (chemical safety assessment) development programme engage industry associations in developing avenues to address duty holders with recommendations and support in fulfilling their obligations. In June, ECHA published a Practical Guide for Downstream Users receiving Exposure Scenarios for substances registered under REACH.

These various activities not only serve to intensify the information that SMEs may already have but also aim at "reaching the unreachable", i.e. any company that may not yet be aware of its obligations under REACH and CLP. Through ECHA's Forum for the Exchange of Information on Enforcement, the Agency has also encouraged national inspectors to use their enforcement activities to raise the awareness of companies that they visit in the course of their regular duties.

I finally want to mention that ECHA's new and totally reorganised website, launched in December 2011, has been instrumental in making information even more accessible to companies. Obviously, this is also to the benefit of SMEs. They can now make use of swift search functions; they can consult regularly updated lists of registered substances as well as those intended for registration by the 2013 deadline; they can access plug-ins that help them use ECHA's IT tools which are also regularly upgraded to match our customers' as well as the REACH processes' needs. User manuals in 22 official EU languages, with screenshots and practical advice, guide customers in using unilingual IT tools. Practical Guides and ECHA's Guidance documents relevant to SME use are made available in translated versions. Since its launch, the new ECHA website is also better accessible in 22 official EU languages, and its translated content is continuously growing. Only such web content which is short-lived or not yet stabilised, and technically complex Guidance documents are not translated; with Guidance in a Nutshell documents and Fact Sheets provided instead. Although all statistical feedback indicates that the vast majority of ECHA's stakeholders make use of ECHA's documents in their original English versions, irrespective of their home country or native language, ECHA is spending about €4 million annually on translating material as a service to its readers, with a view to helping mainly SMEs.

At this juncture, I can only provide a limited snap-shot of our activities of benefit to SMEs; so much is happening and bound to happen still. Nonetheless, even this limited summary underlines that SMEs are close to ECHA's heart. 

Text by Andreas Herdina (pictured above)