Ressourcen

There are different obligations for the different actors within the supply chain. In the simplest case a downstream user has to inform his supplier of the safe handling and application of the substance in case these are known to him. This will, however, not often be the case. So the labour input is rather manageable.

In case the subsequent user has to work out an own evaluation of substance safety, such as every producer or importer is obliged to do, things look different. Substance safety evaluations can, depending on the properties and hazardous nature of a substance, become very extensive and complicated. In the worst case only experts can be contacted who, for example, interpret the toxicological aspects of the substance. But which medium-sized company employs a staff of toxicologists?

The other documentation and communication duties as well, which are required for the registration according to REACH, can only be handled by specialists. Of course, REACH offers a range of software tools and other auxiliary material for practical realisation, but also a database has to be operated and maintained. Not to mention the input and interpretation of data. In addition to that some manuals and technical documents are available in English only. This can also be a problem, since not everybody is aware of the English technical terms.

Another point which emphasises the special challenges of REACH to the resources of a company is the participation of the registrants in the registration fora, the SIEFs. The SIEFs consist of all registrants of one and the same substance. Independent of whether they come from Malta, Poland or Germany. This makes the communication within SIEF complicated. Moreover companies of all sizes can be represented in SIEF: from multinational groups to the small and medium companies who have to resort to totally different resources. While the big groups have entire specialist departments to cope with the tasks of REACH, there are often only one or two persons in small and medium sized companies who are responsible for the "Regulatory Affairs". How does this fit together?

Here we clearly see that a reasonable preparation to REACH is necessary. Besides the technical preconditions to work in accordance with REACH especially the personal resources have to be created or exhausted. But this takes time. A computer can just be bought. An expert in REACH will be found - if at all - after a long search on the employment market. For our customers and partners is important: For several years already we are preparing for REACH and all its aspects and the necessary resources are available.