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Improving REACH ETUC proposals for EVALUATION

Improving REACH ETUC proposals for EVALUATION. François LAURENT ACV-CSC, Belgium. Evaluation. Evaluation = means by which Member States Competent Authorities may examine registration dossiers. There are 2 types of evaluation: Dossier evaluation Substances evaluation. Dossier evaluation.

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Improving REACH ETUC proposals for EVALUATION

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  1. Improving REACHETUC proposals for EVALUATION François LAURENTACV-CSC, Belgium ETUC Conference on REACH - 11-12 March 2005

  2. Evaluation Evaluation = means by which Member States Competent Authorities may examine registration dossiers. There are 2 types of evaluation: • Dossier evaluation • Substances evaluation ETUC Conference on REACH - 11-12 March 2005

  3. Dossier evaluation Dossier evaluation Prevent animal tests + ensure high quality of tests Ensure high quality of dossiers submitted Article 39Examination of testing proposals  request to carry out the tests Article 40Compliance check, esp. waiving statements require information needed for compliance Registrants submit information required Registrants submit information required Check of information submitted  conclusion Check of information submitted  conclusion ETUC Conference on REACH - 11-12 March 2005

  4. Substance evaluation Clarify the suspicion of risks to human health or the environment of a substance Article 44Request for furtherinformation Registrants submit information required Check of information submitted  conclusion Autorisation or Restriction may be needed ETUC Conference on REACH - 11-12 March 2005

  5. Loopholes in the REACH proposal:Dossier evaluation Prevent animal tests + ensure high quality of tests Ensure high quality of dossiers submitted Article 39Examination of testing proposals  request to carry out the tests Article 40Compliance check, esp. waiving statements require information needed for compliance Mandatory for MS Optional for MS ETUC Conference on REACH - 11-12 March 2005

  6. ETUC proposals: • Steps should be taken to discourage the submission of poor quality registration dossiers and to safeguard the quality of information supplied by manufacturers or importers. • Each Competent Authority should be required to check the compliance of minimum 5% of its registration dossiers selected at random. ETUC Conference on REACH - 11-12 March 2005

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