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Päivi Jokiniemi and Paul Trouth
Article related to: REACH
Collaborating for REACH 2018 – SME and consultant perspectives
External service providers can be crucial for SMEs and their success in managing regulatory obligations. Preparing a REACH registration requires time and expertise - something that smaller companies do not necessarily have on top of their daily business routines. Hired help can prove to be a worthwhile investment. We asked an SME representative and a consultancy to give their views on what is important from their side for smooth cooperation.
SME perspective - Services of consultants are often crucial for SMEs and their success in managing regulatory obligations. Preparing a REACH registration is not trivial and the majority of SMEs do not have the sufficient internal know-how to be totally independent from external service providers. Furthermore, the complexity of national and EU obligations often requires the help of a professional, who has an overview of the legal parts that may be relevant for a company.
Just like there are good and bad hairdressers, there are good and bad consultants. Often it is not even a question of good or bad, but whether a specific consultant is the right one for a specific assignment. To clarify this, companies first have to understand why they need a consultant. We have observed that the more knowledgeable the customers are, the fewer misunderstandings that will pop up between them and the consultants.
There are consultants who perform very well. They offer a clear time plan, a clear cost overview, and a clear picture of what they are going to do. However, there are also others who, for example, do not fully understand the data-sharing process or the testing requirements and, as a consequence, cause too high costs to their clients or make the cost planning a bit like a lottery. In principle, a good consultant does not necessarily need to be one of the big players with a lot of capacity. There are also small firms that really understand their job and have an excellent network for additional services they cannot themselves offer.
Finally, there are also good and bad clients. Some companies, for example, clearly underestimate what a REACH registration means. Sometimes they expect miracles for a very low price and in an unrealistic timeframe. A poor understanding of the regulatory requirements and impacts from the client’s side are also sometimes the cause of an ‘unhappy’ relationship with the consultant and end in unpleasant surprises about the actual workload.
Finding the right consultant will usually take time. There are some quality criteria that can support the decision. The Directors’ Contact Group has prepared a checklist to hire a good consultant, which can be found on ECHA’s website.
There are also different educational schemes that guarantee a certain qualification level. One example is the ‘REACH Multiplikator’, a title given by one of UEAPME’s members, the Austrian Federal Economic Chamber (WKÖ), as proof of a successfully completed nine-day course on REACH. These courses ran several times between 2007 and 2017 as a capacity building measure to support better REACH implementation.
UEAPME is the employers’ organisation representing the interests of European crafts, trades and SMEs at EU level.
Consultant perspective - For many small and medium-sized enterprises (SMEs), the 2018 registration deadline is the first time that they need to deliver all the different requirements of the REACH registration process. A large number of these companies choose to cooperate with REACH consultants to get help in successfully fulfilling their obligations. Every SME brings valuable knowledge of their products and industry sector, while consultants bring deep knowledge of the REACH registration process.
REACH registration is substance-specific and involves many steps and interactions with different stakeholders as well as legal and financial commitments. The key to smooth cooperation between consultants and SMEs starts by establishing the range and depth of services needed. This requires high quality communication so that all parties understand what they have to do and why. This helps to avoid problems later on and enables the registration to proceed smoothly.
Several steps are needed at different stages, such as generating substance identity analytical data and substance property data (physico-chemical, toxicological and ecotoxicological), assessing the relevant uses, communicating with all the actors involved (e.g. lead and co-registrants, data holders, substance suppliers and ECHA), and finally preparing and submitting the registration dossier as well as its potential future updates.
It is important to plan an appropriate budget, the required resources and agree on milestones while considering key issues, such as the need to confirm substance identity as a first step before any other REACH registration activities can take place.
Additionally, it is important to note that submitting the REACH registration is not the end of the process. The dossier must be maintained and updated as soon as new information becomes available or when requested by ECHA or the EU competent authorities.
Helen Steele and Richard White
REACH Consultants, Intertek
Intertek is a multinational inspection, product testing and certification company. It has a network of more than 1 000 laboratories and offices, and over 42 000 people in more than 100 countries. Intertek delivers innovative and bespoke assurance, testing, inspection and certification solutions for their customers’ operations and supply chains.
Published on: 16 November 2017
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Biocidal Products Committee:
26 February-1 March
Committee for Risk Assessment:
Committee for Socio-Economic
18-22 March (tentative)
Management Board meeting:
Member State Committee:
13-17 May (tentative)