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Združenje kemijske industrije. REACH awareness workshop Exchange of best practices for the implementation of REACH Janez Furlan Association of Chemical industries of Slovenia Zagreb, 21 st of December, 2007. Association of Chemical Industries.
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Združenje kemijske industrije REACH awareness workshopExchange of best practices for the implementation of REACHJanez FurlanAssociation of Chemical industries of Slovenia Zagreb, 21st of December, 2007
Association of Chemical Industries Exchange of best practices for the implementation of REACH 1. Specific position of Croatia, as an EU candidate country, with regard to REACH. 2. Do “best practices” for implementation of REACH exist? 3. What are the possibilities of exchange of best practices? 4. Experience of the Slovenian Association of Chemical Industries. 5. Recommendations
Association of Chemical Industries Exchange of best practices for the implementation of REACH 1. Specific position of Croatia, as an EU candidate country, with regard to REACH. -Croatia plans to enter EU mid 2009, less than 1 year after the first stipulations of REACH will have to be implemented. - But even before entering EU, REACH will strongly affect the industry through exports to EU. The substances will have to be either registered or pre-registered after 1st of June 2008. - Polymers are exceptions under REACH, but the monomers out of which they are produced, will have will have to be either registered or pre-registered after 1st of June 2008. - Only legal persons, who have a seat in EU can register! - Everything said is also true for exporters of preparations to EU.
Association of Chemical Industries Exchange of best practices for the implementation of REACH 2. Do “best practices” for implementation of REACH exist? - Candidate countries are used to the transposition of legislation, which has been in force for in EU for a long time, so it is to get expertise and best practices from the “old” EU members. - REACH is different: it is new for everybody, so there is no “practices” so far, nevertheless “good practices”. - Implementation of REACH will be a “learning by doing” process for everybody, not only candidate countries. Good practices will be only developed during the processof implementation itself. - An additional problem is, that the authorities of member counties have very poor experience in the enforcement of regulations especially such complex ones as REACH is.
Association of Chemical Industries Exchange of best practices for the implementation of REACH 2. Do “best practices” for implementation of REACH exist? - Enforcement of REACH will be carried out by the authorities of member countries, but REACH provides no tools identical interpretation of its stipulations in different countries and their legal institutions. - The only thing industry can do to avoid problems just mentioned is, to develop its own very qualified expertise and best practices. But this will be effective only if the understanding of REACH stipulations on the industry side will be identical all over EUROPE. The industry must speak with one voice! - The only way to achieve this one voice advocacy is by establishing a wide network, within which commom positions can be agreed upon and best practices exchanged.
Association of Chemical Industries Exchange of best practices for the implementation of REACH 3. What are the possibilities of exchange of best practices? - On national level within the national association. - On international level within CEFIC. - Beware of companies offering their services on a commercial basis, they are right now growing like mushrooms: some are very good, but some are not. One needs some level of expertise at least to be able to tell the difference!
Association of Chemical Industries Exchange of best practices for the implementation of REACH 4. Experience of the Slovenian Association of Chemical Industries. - The association of Chemical Industries of Slovenia became an associate member of CEFIC in 1997. - We became full member of CEFIC in 2001. - 1998 – 1999 Project on chemical legislation - 2001 – 2003 Project CHEMFED/CHEMLEG I . Approx. 220 man days of training provided for experts from the industry and association staff. . Approximately 30 differentexperts were involved - 2004 – 2005 Project CHEMFED/CHEMLEG II . Approx. 50 man days of training provided for experts from the industry and association staff. . Approximately 25 differentexperts were involved
Association of Chemical Industries Exchange of best practices for the implementation of REACH 4. Experience of the Slovenian Association of Chemical Industries. - 2006 and 2007 Cefic grant for RC manager - In paralel to the above mentioned projects, several TAIEX workshops were organised in Slovenia - In paralel to the mentioned above, about 25 experts from the industry and the association staff took part in about 15 different workshops abroad. - We try to participate in WG as much as human and financial resources allow.
Association of Chemical Industries Exchange of best practices for the implementation of REACH 4. Experience of the Slovenian Association of Chemical Industries. - 2006 and 2007 Cefic grant for RC manager - In paralel to the above mentioned projects, several TAIEX workshops were organised in Slovenia - In paralel to the mentioned above, about 25 experts from the industry and the association staff took part in about 15 different workshops abroad. - We try to participate in WG as much as human and financial resources allow.
Association of Chemical Industries Exchange of best practices for the implementation of REACH 4. Experience of the Slovenian Association of Chemical Industries. - Results: . The Association has a strong group of experts (from the industry) on the existing chemical legislation. We are trying to set up a similar group for REACH and GHS. . We have a fairly successfull RC program. . We at least know where to look for expertise we lach within the CEFIC network (CEFIC staff, staff of other association or even industry). . We streamlined our work as much as possible with other associations. We have a proof, that we are doing the right hing: The membership in our association became voluntary in 2006, but NO IMPORTANT COMPANY STEPPED OUT
Association of Chemical Industries Exchange of best practices for the implementation of REACH 5. Recommendations - Do not fool yourselves “REACH” is for EU. It will affect you from 1st of June 2008 and you will anyway be in EU, before you know it, - Make sure your Association has enough human resources to be able to benefit from what CEFIC and its network can provide. - Nobody will bring expertise and help to, you have to start looking for it. The only way to achieve this is to be involved in CEFIC work as deep as possible.
Association of Chemical Industries Exchange of best practices for the implementation of REACH