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It was possible to supply samples of new substances for research and
development, without full Notification under the NONS systems and this is set to continue under REACH. For basic
research, there was no formal requirement to Notify, but to supply samples of over 10 kg for customer evaluation,
it was necessary to consider Process Orientated Research and Development (PORD) Exemption. When REACH comes into full effect (from June 2008), the procedures for exemptions from Registration
will follow the same principles to cover process research, although the procedure will change.
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From June 2008,
the old NONS system of Notification to national Competent Authorities and the system of applying for Process Orientated Research
and Development exemptions in each Member State separately will cease.
If PORDs are in place at
the end of May and further production and process research is required, holders of PORDs will need to apply to ECHA
with proposals for PPORDS under REACH. PORDs will not be 'grandfathered' through automatically.
Effectively, the process will be to notify ECHA of the PPORD request, with justification for the research and if
there is no response to the contrary, supply for production and process orientated research and development can continue.
For
new applications for PPORDs after June 2008, the process is less than clear. However, the criteria set under the old PORD
will be considered minimum requirements - that is the need to identify who is handling / receiving the material, the nature
of the research, justification for volumes and proposals for risk management - there is no formal data requirement, but remember
that exempt materials still need to be correctly classified, labelled and have a compliant SDS to meet supply legislation.
More will be added to this site when details are known.
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