REACH

ALTANA supports the replacement of previous chemical legislation with REACH (Registration, Evaluation and Authorization of Chemicals). However, ALTANA also criticized some parts of the law and expressed its opinion at the political level. We met all specified deadlines to pre-register the substances our company manufactures or imports. As a specialty manufacturer that produces small quantities, we only were required to register two manufactured and three imported substances by November 2010.

ALTANA affiliates that are subject to registration requirements are already working to prepare data submissions that will be due in May 2013.

Lawmakers in the United States are talking about reforming the Toxic Substances Control Act (TSCA).

The local ALTANA companies are trying to interpret the content and assess effects. We also are taking part in a working group on the TSCA reform within the American Chemistry Council (ACC). Since the reform appears to be similar to REACH in some aspects, we will be pleased to share our experiences with the experts in the U.S.

Our cost estimates were approximately right, which upheld our complaint that the expense of the law is tolerable for those producing substances in large volumes, while the expenses for registering smaller quantities (deadlines in 2013 and 2018) will be exceedingly high.

We have also noted that the communication within the supply chain requires expanded material safety data sheets with page counts ranging from hundreds to thousands. The relevant information must be reviewed, evaluated, implemented, and forwarded within the supply chain with additional expanded safety data sheets. This creates a lot of red tape, but greater volumes of printed paper don’t automatically translate into greater safety. We will therefore advocate improvements and practical solutions during the REACH Review 2012.

However, the law certainly has positive aspects as well: More data will be available for evaluating existing substances and customers have better information for the safe use of such substances.