When considering the need to register, attention generally focuses on the need for data review, new testing, deciding on classification and completing the full IUCLID 6 dossier. Even when considering the Chemical Safety Report (CSR) and Exposure Scenarios (ES), guidance is presented as if the reader needs to start from scratch. Most of the guidance is aimed at potential lead registrant or is at least taking an active role in the proceedings.
In reality, many registrants will have a minor role, especially in SIEFs run by larger organisations or consortia, or in cases where the substance is already registered and a letter of access is available for purchase. These (majority of) registrants will only need to conduct the minimal work to be part of a joint registration process, and of course pay data holders for access.
This short guide covers some of the main issues faced by those who are not active towards lead registration, but who will still need to do some work for their own registration.
REACHReady’s aim is to help our subscribers help themselves achieve compliance. A plethora of guidance and articles about REACH and CLP can make it all seem more complicated and difficult than it is, so much of what we do is to remove some of the mystery and fear. We want ...
