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- PFAS – convenience but at what cost?
- Controlling lead in ammunition and fishing – balancing benefits and viability
- Authorities working together to promote safe use of chemicals
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- Get prepared: try out the SCIP prototype now
- Guest column: It is beyond time to act on the PFAS public health threat
- Understanding the value of enforcement
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Get prepared: try out the SCIP prototype now
If your company produces, imports or supplies articles or complex objects (products) containing substances of very high concern included in the REACH Candidate List, now is the time to familiarise yourself with the SCIP database. To help you with this, we tell you more about the prototype that you can already test and introduce some concepts that will make it easier for you to comply with your obligations.
ECHA will launch the first version of the SCIP database by the end of October 2020, but the prototype for it has been available since February 2020. Through the SCIP database, information on products that contain Candidate List substances can be made available throughout their whole lifecycle.
Try out the prototype
The prototype contains most of the features that you will find in the first version of the SCIP database. Although some minor changes will still be implemented, those changes will not affect the main logic and content of the tool. So, if you learn to use the prototype now, you will be able to use the first version of the database, too.
|Clara Rueda. |
Image: Clara Rueda.
|“We really recommend companies that need to notify to go and try out the SCIP prototype. It is there for you so you can familiarise yourself with the tool and explore the ways that data should be filled in and submitted.” |
“We really recommend companies that need to notify to go and try out the SCIP prototype. It is there for you so you can familiarise yourself with the tool and explore the ways that data should be filled in and submitted,” says Clara Rueda, a Scientific Officer working in ECHA’s Exposure and Supply Chain Unit.
In principle, you can use any data to test the SCIP prototype as all the test data will be deleted when the first version of the SCIP database is released in October 2020. After that release you can start submitting your notifications to the SCIP database. The data from these notifications will be made publicly available, with two exceptions. ECHA will not publish the link between the notification and its submitter, nor some specific names or identifiers of product components.
This means, for example, that if there is a notification for a bicycle, the name of the notifier will not be made public, but information about the bicycle, such as the brand and model, will be published. In addition, if the bicycle includes a tyre of a certain brand and model, this specific information will not be made available, but the database will indicate that the tyre of that bicycle contains a Candidate List substance.
To get the best out of the prototype, you need to have a good understanding of the products that you will need to notify later on. “At this point in time, companies should focus on how to describe their products when using the SCIP prototype. Since there are different ways of doing this due to the large diversity of products placed on the market, it is important to test the system so that you are prepared when you start putting together your first notifications,” says Tommy Hägg, working in ECHA’s Computational Assessment Unit supporting the development of the SCIP database.
Simplified SCIP notifications
Many of the products that need to be notified have long supply chains. Even a common product, such as a light bulb, may have a chain of several actors before it reaches its end user. “Let’s assume that a lightbulb is manufactured outside of Europe. This would mean that the importing company has to notify the product to the SCIP database. After that there could be several actors involved in the supply chain before the light bulb is distributed to local stores,” Mr Hägg explains.
In this example, the product stays the same, although it moves from one supplier to another. The good news is, that only the first company importing the product needs to submit the full dataset to the database, and the rest of the actors can benefit from a simplified SCIP notification.
Once the first company has notified the product to the SCIP database, they will receive a SCIP number which they can provide to the next company in the supply chain when supplying the product. The next level company only needs to insert this number into the SCIP database to declare that they are also supplying the same product. As a result, they will receive their own SCIP number, which they can, in turn, provide to the next company in the supply chain.
So the simplified SCIP notification reduces the workload for companies that supply the same product that a higher level supplier has already notified. At the same time, it also helps to maintain confidentiality in the supply chain. “In certain supply chains, who is buying from whom, and at what level, is considered confidential. So, our joint task with the suppliers is to make sure that from the information included in notifications, shared in the supply chain and finally published on ECHA’s website, these can’t be figured out. This approach will also help to reduce duplicate data in the database,” Mr Hägg clarifies.
Referencing helps reduce workload
|Tommy Hägg. |
|“At this point in time, companies should focus on how to describe their products when using the SCIP prototype.” |
The light bulb can also be used as an example to explain another concept that could help companies prepare their data. “If a company assembles a table lamp and places that on the market, they need to notify all the components which contain harmful substances. Some of the components they may produce themselves, for example, the base and the shade, and for those they need to submit the full dataset. But since they buy the light bulb and integrate it in the table lamp, for that they can refer to the data already submitted by their supplier, instead of describing the light bulb again in their own dataset,” Mr Hägg says.
In practice, this means that if a company works as an assembler and does not produce any of the components themselves, their notification could consist of a list of references to others’ data.
Ms Rueda emphasises that creating a notification using referencing requires good communication between different actors in the supply chain but the workload is significantly lower than if a new dataset would be created for each component. It is important to already start planning how to share the information because those companies supplying components to assemblers need to notify as early as possible to allow downstream companies to refer to their notifications. SCIP numbers could be shared, for example, as part of already existing supply chain communication required by REACH.
One of the greatest benefits of referencing becomes clear when there are changes to the original data. Only the company providing the full information will need to update their notification whereas other companies that do not have the details in their notification but only refer to someone else’s data, continue having an up-to-date notification in the system without needing to take any action.
The referencing functionality cannot be tested in the prototype but more information about this will follow at the end of summer 2020.
Important aspects to consider
Sometimes companies may prefer to let someone else, like a consultant or a parent company, submit the data. When adding users to your ECHA account, you can allow other users to act on your company’s behalf. There are no restrictions on how to use the foreign user concept, but bear in mind that you are always responsible for the data submitted in your name and so it is important to have a contractual agreement in place if you allow others to take care of your notifications. You can already test this functionality with the SCIP prototype.
And last – but definitely not least – you need to start thinking about your notification strategy based on the size of your product portfolio. The larger your portfolio, the more resources it will take to manually prepare and submit your notifications. Therefore, you might need to calculate if it makes sense to invest in an IT solution that could ease your workload.
“If you have heard of system-to-system notification, this is what we are talking about. It means that your tailor-made IT system will generate IUCLID dossiers directly from your own data management system and with the help of our programmable interface you can submit them automatically, and follow them in your own IT environment,” Mr Hägg says.
If you need more help to get started, browse ECHA’s website where you can find more information about the SCIP database and your obligations under the Waste Framework Directive.
Start by watching the recording of our webinar that introduces the SCIP prototype and checking the comprehensive Q&A before you start to test the tool. The detailed information requirements for the SCIP database and instructions on how to prepare and submit a SCIP notification are also available on our website.
You can also watch our June Safer Chemicals Conference online to learn more about tracking substances of concern.
Did you know?
SCIP is the database for information on Substances of Concern In articles as such or in complex objects (Products) established under the Waste Framework Directive (WFD).
Companies supplying articles containing substances of very high concern (SVHCs) on the Candidate List in a concentration above 0.1 % weight by weight on the EU market have to submit information on these articles to ECHA, as from 5 January 2021.
The SCIP database ensures that the information on articles containing Candidate List substances is available throughout the whole lifecycle of products and materials, including at the waste stage. The information in the database is then made available to waste operators and consumers.
6 steps to get prepared
Find out more: SCIP database – What you need to know
Interview by Päivi Jokiniemi
Published on: 28 May 2020
Top image: © iStock.com/Grafner
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