REACH

In the opinion of Geert Dancet, Director of the European Chemicals Agency ECHA, the European Chemicals Regulation REACH (Registration, Evaluation, and Authorization of Chemicals) has been a great success. ALTANA supports REACH in principle and its goals (protection of humans and in the environment) without reservations.

However, we advocated for an easy-to-use and efficient regulation in the scope of the political discussion.

A first review of REACH is scheduled for 2012 to look at its first five years in effect. The review will adjust the chemicals regul ation for the future to make it easier to comply with. Difficult ies particularly arise from the expanded safety data sheets and the communication within the supply chain. Most data sheets issued by suppliers for registered substances include hundred or more pages, sometimes even several hundred. By comparison they contain little safety-relevant information. Additionally, the safety data sheets must be available in the corresponding national language, which is not a problem as long as the content is made up of standardized phrases, which can be easy to translate  with specialized software. The “expanded” part contains free text, which leads to significant expenditures for translation.

Because ALTANA primarily works with preparations consisting of multiple substances, this is a major administrative challenge. We have to merge several expanded safety data sheets into a single data sheet for our mixture. This requires intensive expert work to provide our customers with safety data sheets that are not only shorter, but also understandable.

Since we don’t receive the safety data sheets from our suppliers at the same time, the process may need to be repeated several times for a single product. A simplification of this proced ure is definitely required.

It would be helpful to focus on processing conditions and risk management measures. In addition, standard phrases for the "expanded" part are urgently needed. We also believe there is a need for greater cost efficiency for small-volume substances (e.g. with fewer tests). Although the registration of small-volume substances costs significantly less than large volumes in absolute
terms, the costs are much higher on a per-volume basis and may endanger the economic marketing of small-volume substances.

In principle, all ALTANA customers receive safety data sheets about the hazardous properties of products. The corresponding database is continuously expanded by REACH.

We have also noted that the conditions for the safe handling of chemicals have not led to any changes in our facilities. The reason is that the chemical facilities we operate are subject to stringent permit requirements, which focus on risk
management measures to guarantee safe handling for humans and the environment. Changes to facilities would only need to be made if REACH were to result in new toxicology or ecotoxicology evaluations.