ECHA

Dr Fabio Stratta, Technical Director at the medium-sized SME Giusto Faravelli S.p.A., gave his company's viewpoint on the registration process to the participants of the Stakeholders' Day. ECHA Newsletter had the chance to discuss with Dr Stratta the lessons his company has learnt from their registration experiences.

Giusto Faravelli S.p.A. has dealt with the registration process from the very beginning. The company made 400 pre-registrations before the first 2010 registration deadline. This early phase was particularly demanding as the company planned to register a hazardous copper salt in the highest tonnage band.

"To meet such demands, we had to make sure that we had effective strategies in place. From 2009, we made contact with the consortium of members of the SIEF. It was due to early contact with the secretariat of the consortium and its efficient work that we were able to complete the work by the deadline," Dr Stratta explains.

Fabio Stratta at ECHA.

Never too early for 2018

For the 2013 deadline, the company also registered a pair of substances and is planning to register more in 2018. However, as traders, the company is left in a somewhat difficult predicament.

"We, of course, plan to register in 2018 but it is impossible to know at the moment what we will register. In 2008, we initially pre-registered 300 substances and then had to perform 100 late pre-registrations because our customers needed new substances, and some of the suppliers were new and did not have a good knowledge of REACH processes. The previous deadlines have taught us that it is much too early for us to know exactly what substances we will register in 2018," insists Dr Stratta.

Learning from previous deadlines

Having gone through two registration deadlines, the company has learnt many lessons and, in its opinion, the registration process has become easier. "For sure, the first deadline was the hardest for us but we like to think of it as a learning experience. Once you gain this experience, the process runs much smoother," Dr Stratta says.

"For the second deadline, we had some time to employ more skilled personnel, and to train them on REACH processes. We also had the time to put some strategies in place and to create additional tools to make the process easier. However, for 2018 there is a strong likelihood that we will need to rely more on consultants and we will have to hire more people due to the large number of possible registrations," explains Dr Stratta.

Overcoming challenges

"The main challenges are, of course, time and money, but in my view, these problems are always in focus no matter what size your company is," Dr Stratta says.

"What companies have to do, and particularly SMEs, is to try to recover direct costs by saving indirect costs. If you are a small company, you can do this by using your internal resources more efficiently. Check to see what expertise you have in-house. Your colleagues may work every day with regulatory compliance in other fields, and so they will already have an understanding of how to approach regulatory work. What is important though is to give them enough training to grasp REACH. Training your staff should be viewed as an investment, as they can then go on to train other people and help to make the registration process easier for your company," Dr Stratta encourages.

Development of informatics

For Giusto Faravelli, it was also important to assess their own IT systems and develop tools to better suit the company's needs.

"Our systems work with the EINECs numbers. Firstly, we ask for information from suppliers about their REACH position and for documents that show they are in compliance with REACH. Once these data are received, we place these suppliers into our system," Dr Stratta explains.

"If the supplier is European, the system searches for pre-registrations or a registration number. If the data is missing, the system will automatically lock and block the sale of the substance," Dr Stratta continues. "If the supplier is from outside of Europe, the system acts in the same way looking for data. However, in this case, if it doesn't find any information, it will also search for substances covered by Giusto Faravelli, keeping track of the maximum importation limit allowed by the pre-registration or registration we made as an importer for the specific substance," states Dr Stratta.

The substances are then only sold if REACH compliance can be demonstrated by the suppliers in the system.

Challenges for SMEs

In Dr Stratta's opinion, working on indirect costs is the key for SMEs, but an in-depth knowledge of REACH is also extremely important. "Even if you are a small company, you can ask from your trade association to give some advice and support to help you better understand the legislation," remarks Dr Stratta.

"You should not be afraid to approach the authorities. You have to contact them and ask for advice if you are unsure of what to do. They are there to help. This is what we did through our trade association Federchimica and with ECHA, and the support we have received has been vital," Dr Stratta says.

Communication skills are also viewed as integral throughout the process not only in terms of communicating along the supply chain but also internally. "It is really important that there is good communication at all levels of your company. You have to give your colleagues the tools to understand REACH," Dr Stratta reiterates.

Part of these communication skills is to make sure that the company is not looking at 2018 and seeing it as an issue for the future. "You cannot just think about the 2018 deadline as something to be dealt with in a few years. The work should begin immediately," Dr Stratta concludes.

Interview by Paul Trouth