Communication with authorities
Companies may apply several risk management elements to improve chemical safety at the site and of their products and hence reduce risks to human health and the environment to an acceptable level. National inspectors control the implementation of risk reduction targets in companies. National competent authorities and the EU institutions develop restrictions and further EU-wide risk management measures to manage unacceptable risks.
An important element of risk management is communication between companies and authorities in the form of e.g. reporting, applying for permits or licenses or providing information at EU level:
1. Registration of substances with ECHA by submission of a dossier
The aim of registration is to ensure that for all substances on the market, their manufacturers or importers provide at least basic data on hazards, uses, exposures and safe handling. For high volume substances, they are also to assess risks related to the uses of substances and to develop and recommend appropriate risk management measures.
Registration only applies to companies that manufacture or import substances in amounts exceeding 1 t/a (on their own or in mixtures and in certain cases also in articles).
The aim of the notification requirement is to make information on the classification and labelling of any substance on the market available and to promote a uniform classification of substances.
It is relevant to companies that manufacture or import substances:
- subject to registration under the REACH Regulation,
- classified as hazardous, irrespective of the quantity,
- or, in certain cases, import substances in mixtures or articles.
3. Authorisation notification
If a company uses a substance that is authorised by the EU Commission, it must notify ECHA of its use. The information if an authorisation exists can be retrieved from the safety data sheet of the substance or the mixture it is contained in. Details on how a notification needs to be performed are provided by ECHA.
4. Communicating SVHC Information in articles to ECHA
From January 2020 all article producers are to communicate the content of SHVC in articles above 0.1% to ECHA’s new database on SVHC in articles. This database and the related requirements are currently being developed.
5. Further communication requirements
Companies placing active substance on the market or products containing these, i.e. biocidal products, plant protection products or pharmaceuticals are to provide detailed hazard and risk information to the EU and/or authorities beforehand. Specific legislation applies and needs to be followed.