By Dennis Deily
REACH compliance and verification is a responsibility of the competent authorities in each member state of the European Union. However, in order to ensure harmonization, fair and equal treatment and to understand best practices for enforcement, the Forum for Exchange of Information on Enforcement was established as a part of the REACH regulations. The forum is currently chaired by Szilvia Deim who spoke at ChemCon Istanbul on April 11, 2014.
In her discussion, Szilvia reviewed a number of REACH enforcement projects (REFs) and other compliance projects in the EU. Although all member states participate in the REFs, a review of 9 member states’ enforcement findings was presented. Looking at common inspection themes for each member state revealed some common threads:
- Nearly all inspected for key hazard/risk communication elements:
o Classification, Labeling & Packaging (CLP) compliance
o Safety Data Sheet (SDS) compliance
Common findings from these inspections were poor SDS quality and low CLP awareness. These findings resulted in a number of initiatives at the national and EU level that address:
- Increased training
- Better tools
- Awareness initiatives
- ECHA and industry actions to improve SDSs
These findings were mirrored in a 2012-2013 Nordic CLP project that focused on content of SDS sections 2, 3 and 12. 2014 enforcement activities are already underway with renewed focus of the SDS issues as well as downstream user focus on SDS supply to consumers.