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Editor-in-chief:
Johanna Salomaa-Valkamo

Editors:
Päivi Jokiniemi and Paul Trouth

Article related to: REACH

National helpdesks - your first point of contact

For the first time, national helpdesks contributed to ECHA's Lead Registrant Workshop and training held in Helsinki from 11 to 12 October 2012. ECHA invited representatives from the national helpdesks with the largest number of registrants to the event: Belgium, France, Germany and the United Kingdom. The Lead Registrant Workshop offered an opportunity for the national helpdesks to meet lead registrants, and promote their work. The helpdesk experts conveyed an unambiguous message: "We are committed to supporting industry towards the second registration deadline in 2013."

ECHA Newsletter spoke with the representatives of the four REACH helpdesks to learn more about what they are doing in their own countries to help the industry to comply with REACH with the upcoming 2013 deadline in mind.

Suzanne Wiandt.
Image copyright:
Suzanne Wiandt

Dr Suzanne Wiandt from the German REACH and CLP helpdesk says that they offer information and support to registrants through their website, reply to enquiries by email and phone, and organise events to raise awareness of REACH obligations. "We also offer registrants, whose enquiry we cannot reply to by email or phone, or whose issue is complicated, the possibility to come to Dortmund, our headquarters, for bilateral discussions. During these discussions, we take the time to go into the subject and get to know where the problems are, and offer our best advice. The responsibility for the appropriate action remains with the registrant, of course," Dr Wiandt explains.

The German helpdesk receives on average 200 enquiries each month and arranges monthly one to two bilateral discussions with companies. The number of enquiries received has gone down from the peak period in 2008 but the nature of questions has changed. "In the past two years, the questions have become more complex and take longer to reply to," Dr Wiandt points out.

It all starts with substance identity

To promote the 2013 deadline, the German authorities organised a big event for around 200 participants in June 2012, which managed to attract a lot of newcomers. The helpdesk also cooperates with the industrial chamber of commerce to reach smaller companies. "Topic-wise we consider substance identity as one of the key issues for the upcoming deadline. It has to be determined very precisely. We have also focused on the registration of nanomaterials under REACH. Another important issue is communication in the supply chain. If substance identity is the start of the REACH process, communication down the supply chain is crucial for achieving the aims of REACH. There is a lot to be done with harmonisation of safety data sheets," Suzanne Wiandt says.

Dr Wiandt calls on the registrants to follow the principles of joint submission as well as fair and transparent cost and data sharing. "We see big discrepancies in data and cost sharing. Some companies are not willing to share data, or the price of the Letter of Access is too high for a small company. Unfortunately, in the helpdesk we cannot help much with data or cost sharing problems. It is up to the registrants to reach an agreement or ultimately up to ECHA to resolve potential disputes."

The German REACH and CLP helpdesk is located in the Federal Institute for Occupational Safety and Health (BAuA) in Dortmund, but it works closely with different experts from the Environmental Agency (UBA) and the Federal institute for risk assessment (BfR).

German REACH and CLP Helpdesk

Lindsay Peppin.

The REACH and CLP helpdesk in the Health and Safety Executive (HSE) in the United Kingdom is a joint effort of different specialists. "We have a lot of different resources we can draw upon: toxicologists, chemists, biologists, economists and occupational hygienists," says Dr Lindsay Peppin, one of the key staff in the helpdesk. She emphasises that the UK helpdesk does not work in isolation. "We spend a lot of time building up good working relationships with our stakeholders as well as with other national helpdesks. We see ourselves as more of a gateway to a network of resources and I think this is important for companies to realise."

On average the UK helpdesk receives 40 questions per week on the application of REACH and CLP. "For the 2013 registrants we are there to support them as best as we can. According to the feedback we have received from our stakeholders and industry, there will not be many newcomers for the 2013 deadline, so the registrants already have practical experience. However, we do appreciate that each registration deadline is different and brings different challenges: 2013 is about lower tonnage substances, and the calls and emails we receive suggest there is less data available, more testing required or more alternative strategies, like QSARs and read-across, needed. Our support is going to be different in terms of the advice that we give but we will maintain our usual helpdesk functions - answering questions by email and phone or meeting with industry if that is more appropriate," Ms Peppin explains.

Having already experienced one REACH deadline, there is now a good deal of information available and lessons learnt as a result of dossier evaluation. More guidance has also been published to help companies find their way in the REACH registration process. "One of our key roles is helping companies to navigate through all the guidance that is available and helping them work out how it applies to them in their situation," Ms Peppin concludes.

HSE REACH and CLP Helpdesk


Nathalie Hayaud. Image copyright: Nathalie Hayaud	Stephanie Vivier-Copin.

Nathalie Hayaud and Stephanie Copin-Vivier from the French helpdesk say that they work together with the French competent authority, the Ministry of Ecology, Sustainable Development and Energy, and chambers of commerce on a specific national action plan for REACH 2013. "We raise awareness on the REACH registration and try to get companies that might not be aware that they are impacted, involved. We also talk a lot about communication in the supply chain and authorisation. According to our research these are topics that need to be addressed," says Ms Copoin-Vivier.

The helpdesk staff travel to local events to meet industry. "Our message is that if you are impacted by REACH you need to comply for the sake of your business. And we are here to help you do that. I sometimes feel that especially the smaller companies are not aware that there is a REACH helpdesk," Ms Copin-Vivier explains.

The French helpdesk receives on average 250 enquiries each month by email and phone. The quickest way to get a response is to call. "At present, we receive quite many questions from downstream users. They are worried whether their use is covered by the registration or whether they should receive an exposure scenario or not. We try to highlight the importance of communication with the producers and the lead registrant because often there is a lack of information," Ms Hayaud adds.

The helpdesk also publishes its own newsletter and various fact sheets. They can all be found online.

French REACH and CLP helpdesk

Jean-Pierre Feyaerts from Belgium says that the Belgian REACH helpdesk receives around 250 questions annually in Dutch (45%), French (30%) and English (25%). Currently, most of the questions coming in are in English. "Many companies have their main offices in Belgium but are present in different Member States. For that reason they prefer to have the replies in English. It is easier to pass the message inside the company in English. The second factor is that there are quite many Only Representatives positioned in Belgium," Mr Feyaerts says. At present, the majority of questions are coming from consultants working on REACH on behalf of the companies. "These questions in general are not specific for Belgium, so we believe the consultants are working for international businesses."

The Belgian helpdesk is supporting the national federations with their REACH activities. "We attend their meetings and remind people of the obligations of REACH. It is important to work together with the federations. In the helpdesk, we offer information on the legal aspects, whereas the federations can give more practical advice," Mr Feyaerts points out.

FPS Economy – REACH Helpdesk

Dutch

French

Further information:

List of national helpdesks
ECHA reaches out to SMEs and ECHA welcomes Croatia, Newsletter 4/2012
Agency Networking, Newsletter 1/2010
Competent network with a variety of services, Newsletter 2/2010
ECHA Information Desk

HelpNet - the network of national REACH and CLP helpdesks was established in October 2009 to promote consistent and harmonised responses within the EU and to ensure the best possible advice to companies seeking to fulfil their obligations
under the REACH and CLP Regulations.

National helpdesks have an important role as the first point of contact for duty holders situated in their country. They are best placed to communicate with their domestic industry, also giving advice in the respective languages.

Further information

Text and interviews by Viorica Naghy and Hanna-Kaisa Torkkeli