98 JOURNAL OF COSMETIC SCIENCE
(4) Establish a list of your customers and what their uses are also establish whether the substance is being
sold to downstream users and/or consumers via distributors .........
(5) Establish whether there are for your substances:
Hazard property information, i.e. any available studies according to Annexes V through VIII of REACH
[old numbering] or other types of hazard information, e.g. human data or QSARs, of your own or others,
including vertebrate animal tests Classification &Labeling information Safety data sheet (and, if necessary,
bring them in line with existing regulation).
Exposure information across the supply chain i.e. exposures of your own workforce and exposures at your
customers' workplaces and eventually in final uses."
This has much in common with CO LIP A (The European Cosmetic toiletry and perfumery Association)
advice from summer 2006, which for cosmetic manufacturers notably adds the further advice" ...establish
your company's REACH team ...prioritize your ingredients ...proactively start a dialogue with your
suppliers".
What's Croda done so far, what have you learned already?
We have been tracking the development of REACH since publication of the "White Paper" in February
2001. We had even 2 years ago already prepared volume rankings of our finished product range as sold,
aggregated by CAS registry number, adjusted for activity, allowing for exclusions of polymers and
materials on "Annex IV''. This is a significant undertaking by "normal" standards, but one over which we
had control of input and timing. Preparation of an inventory of our raw material is still on-going. This is a
much more difficult undertaking, for example multiple suppliers of the "same" product turn out to assign
different CAS numbers or even mention none on their MSDS, different suppliers have different status for
the same material -sometimes we are the importer, sometimes our supplier is, sometimes our supplier is
the manufacturer- even for the same substance. Our advice is "if you haven't started your inventory yet,
then start as soon as you can".
In terms of responding to customer enquiries we have prepared a position statement that first confirms that
we are aware of REACH and that we know what the requirements will be. It refers customers to the current
status of the legislation and activities on its implementation. We indicate that we are taking part in industry
association activities in preparation for implementation, including identification of possible consortia
partners. However we also make it clear that it is not possible to give absolute undertakings that a material
will be supported through the REACH process in advance (no association we know of is advising any
company that they should be able to reasonably ask for such an undertaking -but this has not stopped
customers from asking!).
Hang on -you've largely discussed activities before and up to pre-registration -we've not even got
to "R" for Registration yet, what about Evaluation, Authorization?
"Learn to walk before you try to run" the activities described above need to be carried out now! You need a
team to start preparing for pre-registration now. There is a lot of information out there about REACH -so
much guidance, for example in "Reach Implementation Projects" that you might need guidance on the
guidance. The first step is to realize that you need to have a team working on the issue -that team can find
more information, and as long as you pre-register and joint a Substance Information Exchange Forum
(SIEF) as foreseen by the legislation you should find partners with a common interest in most substances
who will be forming consortia to supply shared data and reduce cost.
If you've done all this already- congratulations! You have still a long way to go, but you are ahead of
many.
(4) Establish a list of your customers and what their uses are also establish whether the substance is being
sold to downstream users and/or consumers via distributors .........
(5) Establish whether there are for your substances:
Hazard property information, i.e. any available studies according to Annexes V through VIII of REACH
[old numbering] or other types of hazard information, e.g. human data or QSARs, of your own or others,
including vertebrate animal tests Classification &Labeling information Safety data sheet (and, if necessary,
bring them in line with existing regulation).
Exposure information across the supply chain i.e. exposures of your own workforce and exposures at your
customers' workplaces and eventually in final uses."
This has much in common with CO LIP A (The European Cosmetic toiletry and perfumery Association)
advice from summer 2006, which for cosmetic manufacturers notably adds the further advice" ...establish
your company's REACH team ...prioritize your ingredients ...proactively start a dialogue with your
suppliers".
What's Croda done so far, what have you learned already?
We have been tracking the development of REACH since publication of the "White Paper" in February
2001. We had even 2 years ago already prepared volume rankings of our finished product range as sold,
aggregated by CAS registry number, adjusted for activity, allowing for exclusions of polymers and
materials on "Annex IV''. This is a significant undertaking by "normal" standards, but one over which we
had control of input and timing. Preparation of an inventory of our raw material is still on-going. This is a
much more difficult undertaking, for example multiple suppliers of the "same" product turn out to assign
different CAS numbers or even mention none on their MSDS, different suppliers have different status for
the same material -sometimes we are the importer, sometimes our supplier is, sometimes our supplier is
the manufacturer- even for the same substance. Our advice is "if you haven't started your inventory yet,
then start as soon as you can".
In terms of responding to customer enquiries we have prepared a position statement that first confirms that
we are aware of REACH and that we know what the requirements will be. It refers customers to the current
status of the legislation and activities on its implementation. We indicate that we are taking part in industry
association activities in preparation for implementation, including identification of possible consortia
partners. However we also make it clear that it is not possible to give absolute undertakings that a material
will be supported through the REACH process in advance (no association we know of is advising any
company that they should be able to reasonably ask for such an undertaking -but this has not stopped
customers from asking!).
Hang on -you've largely discussed activities before and up to pre-registration -we've not even got
to "R" for Registration yet, what about Evaluation, Authorization?
"Learn to walk before you try to run" the activities described above need to be carried out now! You need a
team to start preparing for pre-registration now. There is a lot of information out there about REACH -so
much guidance, for example in "Reach Implementation Projects" that you might need guidance on the
guidance. The first step is to realize that you need to have a team working on the issue -that team can find
more information, and as long as you pre-register and joint a Substance Information Exchange Forum
(SIEF) as foreseen by the legislation you should find partners with a common interest in most substances
who will be forming consortia to supply shared data and reduce cost.
If you've done all this already- congratulations! You have still a long way to go, but you are ahead of
many.
