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Implementation of REACH: The national REACH-CLP Helpdesk in Germany  Andreas Fleischer

Implementation of REACH: The national REACH-CLP Helpdesk in Germany  Andreas Fleischer Federal Office for Chemicals. TAIEX Workshop on REACH, Belgrade 12 November 2009. Outline. The Federal Office for Chemicals Helpdesk activities: Aims, challenges and co-operation

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Implementation of REACH: The national REACH-CLP Helpdesk in Germany  Andreas Fleischer

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  1. Implementation of REACH: The national REACH-CLP Helpdesk in Germany  Andreas Fleischer Federal Office for Chemicals TAIEX Workshop on REACH, Belgrade 12 November 2009

  2. Outline The Federal Office for Chemicals Helpdesk activities: Aims, challenges and co-operation Pro-active Information services Information on demand Statistics, frequent topics

  3. REACH and BAuA The Federal Office for Chemicals is: • responsible for implementation of statutory regulations to protect man and the environment from hazardous substances. • contact point for the chemicals industry; receives relevant chemical data, which are examined in co-operation with different assessment authorities (environmental, consumer and worker protection). • REACH procedures: e.g. dossier preparation for harmonized Classification and Labelling, SVHC identification, substance evaluation • REACH and CLP Helpdesk • Authorisation procedure for biocidal products • Cooperation with enforcement authorities • PIC/POP • Ozone depleting substances (ODPs - CFCs - chlorofluorocarbons)

  4. Helpdesk – Federal level BMU  Ministry in Charge BAUA FB5  Federal Office for Chemicals BAUA FB4  Hazardous Substances and Occupational Safety BfR Federal Institute for Risk Assessment UBA  Federal Environmental Agency BAM  Federal Institute for Materials Research and Testing Federal states  Enforcement authorities

  5. German helpdesk activities • Member State task / obligation: • To establish a national REACH-helpdesk • (REACH Title XIII Competent Authorities, • Article 124 Other responsibilities) • To establish a national CLP-helpdesk • (Article 44, CLP-Regulation (EC) Nr. 1272/2008 • Aim • To provide advice to companies on their • responsibilities and obligations under REACH • (in particular in relation to registration) and CLP

  6. Challenges for MemberStates in REACH implementation • Availability of resources • To ensure efficient implementation of REACH processes • To ensure appropriate level of Helpdesk support for industry • Awareness raising and training • To prompt companies that still are sleeping • Efficient enforcement • To ensure fair competition within internal market • To ensure that higher level of protection for health and environment is achieved

  7. Access via all communication pathways Fast, qualified and consistent answers Help for self-help Consistency throughout the EU Aims of a REACH-helpdesk

  8. Co-operation - Regional level REACH Helpdesk (BAuA) ECHA - Helsinki Regional Helpdesks e.g. REACHnet (NRW), REACH Help (BW); reach@lgl.bayern.de; etc. Companies (Manufacturer, DU, Importers etc.) Industrial associations Inspectorates

  9. Services offered by the REACH-CLP Helpdesk Taks: Support and give advice to manufacturers, importers, downstream users, distributors and other interested parties with the compliance of their obligations under REACH and CLP Services offered: - Brochures: REACH-Info - Translations - Internetportal: www.reach-clp-helpdesk.de - Seminars / Workshops - Other awarness raising activities (e.g. press releases, presence at trade fairs, …) pro-active • - Presentations • Expert meetings/consultations • Answers to direct inquiries on demand

  10. Internet portal

  11. www.reach-clp-helpdesk.de www.reach-clp-helpdesk.de • News • Important deadlines • Topics A-Z • Decision Tree • Legal texts and guidance • FAQ • Glossary • Events • Brochures

  12. REACH-CLP Helpdesk – Information material REACH-Info: Series of brochures • New 2009: • REACH-Info 6 Articles: Obligations for Producers, Importers and Distributors • Planned 2010: • REACH-Info 7 Recycling

  13. Workshops Organization of BAuA-REACH events (approx. 250 participants): 14.10.2008 REACH: New trends! 04.11.2008 REACH, Recycling, Waste – what should be done? 26.03.2009 SIEF, Consortia and joint submission 07.05.2009 GHS and its implementation in the EU 17.09.2009 Registration dossier 13.10.2009 Exposure assessment 03.12.2009 Information requirments

  14. Infocenter at BAuA Answer Back-Office BAuA Division 5 Expert UBA, BfR, FB4, BAM, EU-Network Knowledge base/ Publishing FAQs Expert Expert REACH Helpdesk – Answering Questions Manufacturer, Importer, Downstream User Question Dialogue reach-clp@baua.bund.de

  15. logo Address contact & phone tailored made answer Reference number disclaimer

  16. Statistics • Answers within 1 – 6 weeks depending on complexity of question (e.g. concerning UVCB*; example: enzymes) • Several “difficult” questions identified, which are fed into the EU helpdesk network (e.g. concerning ‘only representative’) • Questions were asked by IHKs, SMEs, REACH-consultants, big companies, and by Asiatic stakeholders * Substances of unknown or variable composition, complex reaction products or biological materials

  17. REACH-CLP Helpdesk Statistics Inquiries to the REACH-CLP Helpdesk Entering into force of REACH Start of preregistration period End of preregistration period

  18. REACH-CLP Helpdesk Statistics: Topics Top-Issues 2009 Registration 29 % Preregistration, SIEF 11 % Supply chain 9 % Exemptions 9 % Inquiries 2009 by topic Inquiries 2008 by topic Top-Issues 2008 Registration obligations 52 % Exemptions 15 % Downstream users 12 % Preregistration 9 %

  19. Information Centre – Front office

  20. Expert meetings / consultations About 40 expert meetings in 2008/2009 with industry took place on: • steel works / smelters • metals • glass • how to test / register difficult substances • cosmetics, cleansing products • paper industry • nano-materials • etc.

  21. Presentations Helpdesk staff, giving talks at chambers of industry and commerce, e.g. IHKs invited BAuA-speakers for specific REACH-events 2008/2009: approx. 50 events Topics: Recycling Substance Identity Preregistration Introduction to REACH Polymers

  22. Scope - Resources • Scope of national helpdesk at the BAuA: • provides advice on technical issues, even of complex scientific nature • however: German federal helpdesk not responsible for registration obligations of industry! • Resources involved at BAuA – notification division: • currently for helpdesk activities approx. 10 staff involved (however not fulltime). • however: more resources needed for increased support demands by SMEs and support on CLP in future

  23. Frequent Questions regarding Textiles • What is a substance, intended to be released (Jeans loosing colours???) • Borderline cases, fibres: substance vs. article • Restrictions of substances in textiles • Information obligations (Art. 7, Art. 33) • SVHC, e.g. Flame retardants in textiles • Communication in the supply chain on SVHC

  24. Finally: How to contact the German Helpdesk reach-clp@baua.bund.de Phone: 0231 9071-2971 – Fax 0231 9071-2679 (Monday-Friday 8.00 – 16:30 h) www.reach-clp-helpdesk.de Thank you for your attention!

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