REACH compliance checks
- Registration liability
- SVHC exposure in Articles or substances
- Supply line options
- Only-representative processes
SDS Compliance checks
- Up to date with latest requirements
- SDS authoring
CLP Compliance checks
- Classification / Labelling
- Special cases
- Poison Centre Notification (PCN)
Compliance Audits and Systems
As well as REACH and CLP compliance for registration, classification, SDS etc, the regulatory framework in Europe includes many other aspects such as off-shore chemical use, biocidal products, consumer legislation, food contact etc. and those manufacturing or trading in chemical products need to ensure compliance.
Much of this is customer driven with awkward questions from those using the products wanting assurance that their uses are covered.
It is important to have a ‘system’ in place to monitor chemical substances and blended products and to ensure that those in your organisation know their respective roles.
Compliance checks by Denehurst
Work is typically performed on-site, but will generally involve preparation activities before a visit and reporting after on-site assessments. To get the most out of the checks, various members of senior management need to be involved, including technical, purchasing, sales and production.
A typical audit would normally involve a total of two days work (one day on-site and several hours for preparation and writing-up). For on-site visits outside the UK, some extra travel time may need to be factored in (typically a half day for most of Europe, but more for the US or Asia).
Costs are typically £1000 / €1300 per day plus expenses, including a report back to the sponsor.
Having a system
Every organisation will have a different way of working and the systems used may be dictated to by multi-site (or even multi-national) management procedures that govern procurement, development of SDS, marketing, legal and so one. However, irrespective of how the organisation is set-out, there needs to be a clear procedure to identify responsible individuals and sites that are involved in certain activities.
Some companies have complex software and IT systems to manage the multi-departmental procedures, but others may use paper systems or simple spread sheets. How it is done is not important, as long as nothing falls between the cracks. It is also important to have a system to prevent a blame-game or passing the buck; trying to avoid responsibility is a skill many of us have, but is not conducive to an efficient and compliant work place.
Who handles the receipt of SDS ?
Who ensures updated SDS are passed to those writing new ones or those implementing health and safety ?
Which site is the official ‘importer’ for CLP notification and REACH ?
Who has reminded the R&D laboratory that CLP applies to imported samples ?
Who check labels of products from the US site before being passed on to EU customers ?
There are many issues and responsibility must be shared with senior management support; it is all goes wrong, it is the senior management who are held to account by the regulatory agencies.