REACH training – what do you need?
SATRA is assisting companies around the world by instructing their personnel in the workings of REACH.
by John Hubbard
Before the European REACH regulation (1907/2006) was published in 2006 (‘REACH’ being an acronym for ‘Registration, Evaluation, Authorisation and Restriction of Chemicals’) many industries believed that the main impact of the proposed new legislation would fall on the European chemicals industry. Apart from manufacturers ensuring continuity of supply for the substances used in processing, it was thought that effects on the consumer goods supply chain would be minimal. However, it soon became apparent that REACH would also impact further down the supply chain, including on suppliers of consumer goods (articles).
This meant that action was required by organisations – whether manufacturers, importers, distributors or retailers – to ensure that they could respond to the regulatory requirements. As the legislation is complex and far reaching, SATRA developed advisory training, initially to raise awareness of the legislation. This progressed to discussing materials, substances and routes to compliance.
SATRA seminars and courses
Over recent years, SATRA’s REACH and Restricted Substances courses have been some of the most popular training events we have run at our Kettering, UK and Dongguan, China facilities. We normally schedule at least two of these a year, with bespoke courses also available for individual members as and when required. The courses continually develop to take account of changes to the legislation and interpretive decisions made by the European Chemicals Agency (ECHA) – the body which administers and coordinates REACH requirements and activity across the European Union (EU) and the European Economic Area (EEA). This training is aimed at technologists and buyers, in addition to quality and safety representatives from across the supply chain. The focus of the day is on the requirements for ‘articles’, the definition of which includes most consumer goods such as footwear, apparel, furniture and sports equipment.
The types of organisations that attend these events include manufacturers who produce within the EU, importers of goods manufactured outside the EU, distributors, retailers and user organisations. These events are kept informal and involve a relatively small group, so that delegates can confidently ask the questions they need have answered, while sharing experiences about working with the REACH regulations.
Typically, the course will cover i) the background to the legislation, ii) the requirements for ‘articles’, including those relating to restricted substances (Annex XVII) and Substances of Very High Concern (SVHCs), iii) laboratory testing regimes and iv) the use of Restricted Substances Lists (RSLs).
At some of these events, we invite guest speakers from external organisations to give an overview of the regulatory framework from a different perspective. These have included the British Retail Consortium (BRC) and UK Trading Standards.
Of worldwide concern
The global nature of the consumer goods supply chain has created interest in understanding the REACH regulations from across the world. SATRA has provided training in a number of regions – either as dedicated seminars, as part of a wider training programme or tailored training for organisations. These training events have been held in China, Indonesia, Italy, Malaysia, Sri Lanka, UK, USA and Vietnam. While the responsibility for compliance with REACH lies with the organisation first importing the goods into the EU, it is often beneficial to provide training and guidance close to the manufacturing site so that suppliers can know first-hand what their customers will be expecting from the products with respect to chemical safety.
One important aspect when deciding on a REACH training course for your staff will be what level of knowledge is required. For technologists who are taking direct responsibility for REACH within the organisation, the full-day REACH seminar is the best starting point. A number of organisations have followed this with a tailored consultancy, specifically relating to their product range or to answer questions that have been raised internally or with their customers. However, for customer service personnel who are responsible for responding to consumers’ requests about the presence of SVHCs in their products within the 45-day time limit, the main training outcome will be to be able to recognise this type of request and to direct the enquiry to the correct department for a timely response. SATRA offers REACH overview training which helps customer service teams to understand their obligations and respond accordingly.
Photograph at top of page shows the author conducting a REACH training course at SATRA's Kettering headquarters
How can we help?
The next REACH seminar will take place on 7th April 2016 in the UK. Please email email@example.com for further information, or if you have requirements for bespoke training for your organisation on any aspect of the regulation. SATRA is also looking to develop web-based training modules for REACH – please let us know if this is of interest to you.
This article was originally published on page 34 of the December 2015 issue of SATRA Bulletin.