ECHA

REACH and CLP requirements are the same for all companies, regardless of their size. But when it comes to implementing the law, what works for large businesses may not be a solution for small and medium sized ones (SMEs). The Belgian Federation for Chemistry and Life Sciences, essenscia, has found a way to make the experience of large companies beneficial and valuable to SMEs.

Around 70 % of essenscia's members are SMEs. "The aim of our mentoring project is to help small companies to understand REACH in a way that they are not only able to comply with it, but also to make strategic choices regarding the sustainability of their portfolio," says Ms Tine Cattoor, product policy adviser of essenscia and manager of the Vlaanderens REACH and CLP Implementation Project (VLARIP).

 

An ambitious but simple idea 

The scheme, which is implemented in the local languages of the two Belgian regions Flanders and Wallonia, is based on learning by doing and sharing experience. Some of the big companies, which are members of essenscia's working group on REACH, agreed to spend a few hours each month to help SMEs. Since these companies were among the first to start implementing REACH, they were able to act as mentors. The mentors help the SMEs to understand what steps need to be taken to meet specific REACH requirements and how to manage the challenges on the way.

"In every case, the mentor already has practical experience of REACH and can give advice to those who do not," Ms Cattoor explains. All tips and advice have been gathered into factsheets and shared with all the programme participants.

The mentoring programme is a good way for SMEs to also share experience among themselves. In many small companies, there may only be one person working on REACH. "Since they have no one else in the company to discuss with, the project is for them like a sounding board," Ms Cattoor says.

Participants work in fixed groups of around 20 SMEs. Two permanent mentors are assigned to each group and other mentors, who specialise in specific topics, join the discussions when they are needed.

 

Developing the scheme

When the project first started in November 2007, nearly 60 of the SMEs were from the chemical industry. One year later the scheme expanded beyond the chemical sector and included three new projects which focused on companies that are end users of chemicals, the textiles sector and the services industry.

The textiles project, which was developed in cooperation with the Belgian textile federation Fedustria, continued for three years. One of the concrete results of the project was a user manual that was created to help textile industries to implement REACH. The services project aimed to bring together different service providers that SMEs needed to be able to comply with REACH.

 

The benefits

To date, 154 SMEs have been involved in the projects in Flanders and 139 in the Wallonia region. Many of those who started in 2007 still participate and new SMEs are joining all the time. The project would not have been possible without the involvement of the big companies acting as mentors. Most of the companies, such as BASF, Agfa-Gevaert, 3M, Borealis, Honeywell, Solutia/Eastman, EOC Surfactants, have provided mentors from the very start. Smaller companies have now also become mentors in the scheme.

A recent survey among the participants found that 98 % have been satisfied or very satisfied with the programme. Four out of five companies said that they have now integrated REACH into their business strategies. 33 % have developed or used new or alternative products or production processes with less impact on health and the environment. For Ms Cattoor, one of the biggest achievements is that SMEs now have a knowledge base, which enables them to take strategic decisions for themselves. They see REACH as part of their business strategy and not just as a set of legal duties. She says that thanks to this mentoring scheme, essenscia understands the needs of their member companies better and how best to help them.

Until 2013, the projects were co-funded by the European Regional Development Fund and by the regional governments in Flanders and Wallonia. This funding is now over for Flanders, but, based on the commitment by both mentors and SMEs, essenscia is continuing with the scheme to help companies to get ready for the next deadline.

 

Tips for SMEs based on the project   Don't be afraid to ask for help. Update your chemical inventory regularly. It is the basis of your business strategy. Hold an information session for colleagues at least once a year, especially in the purchasing department, to explain what their REACH responsibilities are. If you have to pay a registration fee, make sure you have a procedure for your accountancy department to pay quickly. If you use a consultant, make sure you understand each other and that the consultant speaks fluent English so that they can communicate efficiently with other registrants and ECHA. If you rely for your imports on an Only Representative, make sure you check each year that your imported quantity is covered by the (pre)registration. If you have to register many substances for 2018, start first with those that are already registered by someone else.

 

What do the participants say?

Sofie Van der Looven, Product Steward, Vertexco

"I joined VLARIP at a very challenging time for our company, which has less than 10 employees. We assumed a new role in the supply chain and had to comply with new obligations under REACH. Until 2010, we were only a distributor of dyeing, finishing and fibre lubrication products for the textile industry. Then we also became a formulator. This was just after the first registration deadline. The new extended safety data sheets had started to move in the supply chain. It was difficult for me to work with them and joining the project was a great help. I managed not only to learn, but also to do a lot myself thanks to the support and practical advice of the mentors. The project team listens attentively to our needs and provides practical responses."

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Annick D'hulst, HSE Manager, Cappelle Pigments NV

"In 2008, Cappelle Pigments was a medium-sized enterprise in the pigment manufacturing sector, and we joined VLARIP from the start. The support and exchange of information was very useful and through real, live demonstrations (e.g. CLP notifications) it was shown that SME's can fulfil their obligations to a large extent themselves and do not have to rely so heavily on consultants. The REACH support meetings are less frequent now and the project was extended to REACH related and downstream legislation. As chemicals legislation is continuously subject to further development and modification, Cappelle Pigments – although now no longer considered an SME – continues to take part in Vlarip for information and support."

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Raf Leyman, Regulatory Affairs Manager, Buckman EMEA

"Our company, which has a core business in paper, water, leather technologies and performance chemicals, joined the project from the start. We wanted to build up our REACH network and to share experience with other participants. The registrants' working group provided a lot of support for preparing our registration in 2013 – I learnt from the best practice and the issues faced by companies which had to register in 2010.

Encouraged by this experience we took the lead of two "dormant SIEFs" for the substances we had to register in 2013 in order to progress and make the data set complete. By following the advice we received, we completed and submitted our dossiers on time. We can use the project members' expertise at any time when we need clarification on anything. Last but not least, the project experts informed us about how to best prepare for and deal with national REACH enforcement campaigns and it worked out when the inspectors came."

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essenscia   The Belgian Federation for Chemistry and Life Sciences is an umbrella organisation with 800 members. 70 % of them are SMEs. Essenscia is a member of the European Council of Chemical Manufacturers' Federations (Cefic) and the Federation of Belgian Companies (FEB). Its mission is "Improving everyone's quality of life". http://www.essenscia.be/ http://www.essenscia.be/en/vlarip

 

Text by Virginia Mercouri

Top image: ECHA

 

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