Thursday, August 16, 2007

DSM Details Reach Response

Chemical firms across Europe and beyond are having to come to terms with Reach, the European Union's recently introduced environmental legislation. Multinationals and small companies alike will be affected by the legislation. Here's an uncut and candid detail from specialty chemicals firm DSM on how it is approaching Reach.

DSM's input is from Environment Manager Jan Berends and DSM Board Member Jan Zuidam.

As a company involved in both fine and industrial chemicals, what are the main challenges you face in preparing for the registration phase of REACH next year?
First of all we are working on a complete inventory of all substances that are in our products, raw materials and intermediate. All these substances have to be 'pre-registered' before the end of 2008. Our suppliers have to register the substances they produce or import, DSM has to register the substances in our intermediates and our products. We also collect all information that we have about the relevant substances that is needed for the registration.
In 2007/2008 we will have to assure that all essential raw materials will be (pre-) registered. We will ask our suppliers. In case suppliers are not wiling or not able we will have to act ourselves (register, change of suppliers, etc.)
We are also aligning our risk assessments, because our suppliers need to know the use and exposure of the substances they deliver to DSM. REACH requires that this is mentioned in the registration.
Main challenge is to do this 100% for over 500 products and over 5000 - 10.000 raw materials and thousands of suppliers.

How will the new regulation affect your activities in practice? (i.e.: which sectors of your activities and/or products will be affected first or most heavily?)
On short term extra work as indicated above. The largest impact we now expect is on sourcing of raw materials. E.g. additives (even non-hazardous) might be no longer available on the EU market because the importer/producer does not want to take the burden of registration. However we have to explore this better and not speculate. It should be taken into account that the period for registration for smaller volumes lasts until 2015 of even 2018. So we have to see and act accordingly.

How do you see REACH as an impediment to DSM’s activities? Conversely, how do you see the regulation as an opportunity for your company?
In first instance there will be uncertainty which is not good for the business in EU. There might be some opportunities, however as long as the EU is different from other parts of the world you can argue whether this might really turn into a benefit. Replacing hazardous substances by less hazardous has been a drive already for many products already for a long time. Companies already have the 'duty of care' It remains a question what the added value of REACH will be.

Do you expect your company’s results to improve or deteriorate as a result of REACH? Why? Are you planning to relocate some of your activities?
We now do not expect big impact relative to the trend. Probably we can benefit to some extend from our bio-based orientation (less hazardous substances used and produced) and our long history of responsible care activities (e.g. product stewardship, quality of product information, etc.)

If you were to introduce changes to the regulation what would they be? What would make REACH work better in your view?
I would look for simplification of the registration dossiers depending on the type and the use of a substance. You don't have to know 'everything about everything', but just what is relevant in the different uses. So a more risk based approach. This in fact is the approach as applied in the EOCD HPV-program. And rather than making it full proof in the EU I would spend some energy in global harmonization, since products are being produced and used worldwide.

--Alex Scott, Senior Associate Editor, Chemicalweek magazine


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