ECHA

Yara International ASA is the world's leading provider of nitrogen-containing fertilisers and industrial chemicals, with a presence in 51 countries. Our company operates in all of the roles defined in the REACH Regulation: as a manufacturer, downstream user, importer and an Only Representative (OR) for some of our non-EU subsidiaries.

Implementing the various aspects of REACH consistently throughout the whole organisation has been a challenge. Organisational and management structures have been put in place, both centrally and regionally, to help us address this challenge.

Central organisation

The first step was to establish a central service department, Yara Chemical Compliance (YCC). It has staff specialised in REACH, CLP, chemical safety and global chemical legislation.

This central service department provides expert advice and guidance to the different Yara legal entities and manages registrations and notifications on their behalf. It also prepares safety data sheets for all of Yara's products, which for the European legal entities also means preparing relevant exposure scenarios. In addition, the Yara Chemical Compliance department represents Yara in several industry associations and in ECHA's working groups. However, despite its central role, ensuring REACH compliance is in the end the responsibility of each Yara legal entity.

Quality standards guide the work

Managing REACH and CLP obligations successfully is possible only if the company management is committed to promoting and supporting the work. Legal requirements need to be part of the company's quality management system. To support this, Yara publishes technical and operating standards (TOPS) centrally, which describe the mandatory internal requirements for important operations. The application of these standards is monitored by internal audits.

One technical and operating standard that is mandatory for all legal entities describes the responsibilities for compliance with REACH and other related regulations. This standard explains, for example, that preparing Yara's safety data sheets is a central responsibility whereas the individual legal entities are responsible for requesting, validating and releasing them, as well as for compliance in purchasing, manufacturing and sales.

Regional organisation

In each Yara legal entity based in the EU, a REACH Regional Contact person is nominated. The Yara Chemical Compliance department regularly invites these contact persons to meetings to discuss REACH and CLP related topics, organises training sessions and offers tools to support the legal entities to stay compliant with REACH. The Regional Contact persons are responsible for cascading the information in their legal entity.

In addition, the Yara Chemical Compliance department supports the legal entities by making sure that they receive up-to-date instructions on how to implement REACH and CLP, answering their questions and assisting in solving any non-compliance problems. Issues can vary from assessing the REACH compliance of new suppliers of raw materials, to checking the incoming extended safety data sheets and to spreading awareness of new chemicals added to the Candidate and Authorisation Lists or the List of Restrictions. Continuous maintenance and preparation of compliant safety data sheets for Yara products is a key part of the service.

Keeping the whole organisation up-to-date

To maintain the high level of awareness about REACH in the organisation, good communication and easy access to documentation are essential. All REACH relevant documentation in Yara is centrally archived on the intranet. The legal entities and users have controlled access to the documents relevant for them. The libraries work as repositories to store decisions and all steps of the REACH and CLP processes.

All documents, for example, on registrations, chemical analyses, lists of identified uses, inspection reports from authorities, business decisions, training materials, and customer and supplier communication are accessible to the personnel who need them. In addition, each legal entity is equipped with a local intranet platform where they can store relevant local REACH documents. These can also be shared with the Yara Chemical Compliance department. In addition, the YCC department uses the intranet to regularly post news to key people in the organisation.

For Yara, implementing REACH is not a one-off task. It requires continuous follow-up on changes and updates in regulations and guidelines as well as in the releases of IT tools such as IUCLID 5 and REACH-IT.

In addition, certain changes will trigger an update to a registration and/or the chemical safety report. For example, manufacturing processes or raw materials may change and lead to changes in the composition of the registered substance. Similarly, a new customer application may arise and trigger not only an update of the uses in the chemical safety report but also subsequent updates of all relevant (extended) safety data sheets. A change in substance classification is another event that gives rise to updates. In practice, this means continuous work to improve the quality of registrations and keep them up-to-date.

Working together

Overall, REACH demands that both the central and site organisations are prepared for changes and adjustments. The Yara Chemical Compliance department is designed to react to these changes in time. However, REACH implementation would not be successful without the contribution of plant managers, process engineers, laboratory analysts, site health, environment, safety and quality managers, or without the experience of our procurement, sales and marketing organisations.

Communication with the authorities and industry associations is also important. We are all working together towards a common goal.

We have learnt that good communication between central and local organisations as well as active internal and external networking are essential for applying REACH successfully.

According to Yara, good communication and easy access to documentation are essential to maintain awaress about REACH. From the left: Marie Bjørgan, Reetta Puska, Riccardo Mulato and Inger Aandahl Raastad. Image: Yara.

Yara International ASA   Delivers solutions for sustainable agriculture and environment. Global presence with operations and offices in 51 countries and sales to more than 150 countries. Headquarters in Oslo, Norway. Employs around 10 000 people. http://www.yara.com

Text by Riccardo Mulato, REACH Director, Yara Italia S.p.A.; Reetta Puska, REACH Manager, Yara Suomi Oy; Inger Aandahl Raastad, REACH Manager, Yara International ASA; Marie Bjørgan, Chemical Compliance Specialist, Yara International ASA