Our Prepration to REACH

When you have read the detailed descriptions of the various elements of REACH or already have learnt something about REACH, you will probably ask yourselves: "How can this be handled? From where shall we take the resources, and what does this cost?" These are the questions we asked ourselves as well already in February 2001 when the EU commission presented the so-called White Book on the "Strategy for Future Chemicals Policy". Already at that time it could be seen that a medium sized company will not be able to cope with REACH without intensive preparation and assistance.

Our preparations include all aspects of REACH and all future requirements:

• Identification of our tasks within REACH and continuous briefing of the responsible persons in the company on the future requirements
• Definition of responsibilities and provision of the necessary resources
• Identification and quantification of the flow of substances within the BECHEM group
• Identification of strategic raw materials which could be subjected to authorisation and limitation procedures according to REACH, or which could disappear from the market for economic reasons as well as the intense discussion with the corresponding suppliers
• Procurement and provision of information within the supply chain
• Provision of REACH relevant information for our customers and partners as well as fair and open discussions on the availability of our products

These activities are carried out and controlled by the experts of our product safety department. Besides the technical aspects of the preparation we have also cared for the personal resources. Our staff members have prepared themselves to all aspects of REACH in internal and external training courses. From the new material safety data sheets to the preparation of safety assessments, from the new communication along the supply chain up to the work in the international SIEFs.

We closely monitor the process of the REACH Implementation Project (RIPs). Of course, we know the preliminary results of the RIPs as well as the currently available guidelines on the homepage of the agency and have integrated this information in our preparations. As soon as the individual RIPs are finalised we will implement their results in practical guidelines and operating instructions.

Furthermore we are active in the German and European associations VSI (Association of the Lubricant Industry), UNITI (Federal Association of Medium Sized Mineral Oil Companies) as well as ELGI (European Lubricating Grease Institute). Thus we are forming ties with "companions". This creates certainty and additionally strengthens our position. Furthermore we participate in the creation of a consortium within the ELGI which will meet on a voluntary basis in order to more smoothly cope with the complex tasks of REACH in the community.