Interview with Dr. Kirchner

“The events are a good fit for our overall concept”

Dr. Kirchner, how far has the imple- mentation of REACH advanced at BYK? What was accomplished in 2009 and 2010?

We successfully registered two compounds in 2009 and 2010. This involved a compi- lation of the required toxicology and ecotoxicology data by an external institute with a summary in a dossier. The data were submitted to the European Chemi- cals Agency (EChA) in Helsinki. We also registered all substances that meet the criteria for so-called transported isolated intermediates. We already have the results of the required studies in hand for five additional compounds so that further reg- istration dossiers can be generated and submitted during the course of this year. This year, we plan to start three additional registration projects and three to five substances will be addressed annually in the future. By the end of 2016, we will have completed the submissions for all substances that require registration.

In this context, can you provide more information on the customer seminars and Downstream User Days organized by BYK?

We discovered in numerous conversations with customers that downstream users did not have sufficient knowledge and understanding of the obligations of the REACH Regulation. This caused BYK to develop our so-called “BYK Down- stream User Days” to close these knowl- edge gaps for our customers. The content focuses on the needs of product users and we offered presentations to explain the obligations and measures associated with REACH, which included practical examples and discussions for better un- derstanding. Overall, we organized six of these seminars in the past two years with a total of about 250 participants from

mostly European countries. The events were held in Germany, France, Italy, and Switzerland. Further seminars will be of- fered as required in the future.

What was the customer feedback and what was the significance of these two types of events?

The customer response was consistently very positive. Attendees particularly liked the focus on downstream users. Our documentation with “ready to use” forms and checklists also won praise. This event series is a good fit for our overall service concept. It underscores that BYK and ALTANA offer more than just a product; our products always come with the corre- sponding service.

Which new challenges will BYK face as a consequence of REACH in the coming years?

There are three substantial 
1. Registration of new and imported sub- stances,
2. Obligations for downstream users, and
3. Availability of source materials.

We have already addressed many points for Item 1, including the identification of the affected substances and the selection of the required tests. The next steps will be to perform the examinations and to create dossiers. Item 2 will require the revision of virtually all safety data sheets to adapt them the new requirements. This requires structured communication along the supply chain and outstanding expertise in handling toxicology and ecotoxicology data. Regarding Item 3, BYK has identified all critical source materials and has contacted the suppliers. This is essential to make sure we recognize changes in classification and shifted or discontinued production as early as possible to take proper countermeasures.