Ireland is a member of the European Chemical Agency’s (ECHA) Forum for Exchange of Information on Enforcement (Forum). This is a network of member state authorities responsible for the enforcement of the REACH, CLP and PIC regulations. The Forum is composed of one representative from each Member State. The Forum appoints its own Chair and two Vice-Chairs from the members of the Forum. HSA Inspector Sinead McMickan is currently one of the Vice Chairs of the Forum.

Coordinated and harmonised enforcement is a key factor in the success of the REACH, CLP and PIC Regulations and this is one of the main goals of the Forum. The Forum coordinates various enforcement projects, one of the main ones being the REACH-EN-FORCE (REF) projects which are designed to harmonise enforcement in each Member State and check the current level of compliance with regard to particular obligations imposed on industry by the REACH, CLP and PIC Regulations. To ensure that HSA inspectors have the right tools, training and information to carry out efficient and effective enforcement, the Forum arranges a yearly Train the Trainer event focused on the needs of the inspectors.

Ireland has now taken part in five REF projects and is preparing for the REF 6 project on Classification of Mixtures in 2018. The HSA has just completed REF-5. The focus of REF-5 involved checking consistency of extended Safety Data Sheets (eSDS) with the relevant Chemical Safety Reports (CSR), on supply of eSDS of substances providing safe use information to downstream users (DU) and implementation of risk management measures (RMM) and Operational Conditions (OC) at the workplace.  As a consequence, registered substances manufactured or imported over 10 tonnes per year requiring a Chemical Safety Assessment (CSA) and CSR were subject to REF-5. In addition, ECHA identified substances of particular interest for REF-5 so they could assist in providing information to enforcement agencies. These substances included formaldehyde, ethanol and styrene and the HSA identified sites manufacturing or importing these substances for inspection using authorised searches of ECHA’s portal dashboard for national enforcement authorities (PD-NEA).

HSA inspectors from the Chemicals and Prevention Division visited 13 sites ranging from manufacturers to end users of chemicals where 28 substances were checked including the 3 substances identified by ECHA. Those Manufacturers/Importers visited were largely fulfilling REACH obligations relating to eSDS preparation and communication in the supply chain. Only 1 in 4 of the distributors inspected has eSDSs for the substances checked.  Five of the 9 downstream users checked had received eSDSs and four were compliant with the described operational conditions and risk management measures. Formal enforcement and written advice was issued by inspectors at various sites were non-compliance or other issues were identified. The HSA will report its findings in full to ECHA in Q1 2018. The final REF-5 project report from the Forum is foreseen in Q4 2018.

For further information on the work of the Forum, please visit the following ECHA webpages.

https://echa.europa.eu/about-us/who-we-are/enforcement-forum

Source: HSA E-bulletin

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