On June 1st the six months period for pre-registration of substances manufactured and imported in the EU under REACH started. REACH, the European chemical substances legislation aims to enhance the protection of human health and the environment by knowledge about hazards posed by chemical substances, and by applying appropriate risk assessment for the handling and use of such substances.

REACH requires industry to take responsibility for managing risks posed by chemical substances and applies to all companies that manufacture, import and use chemicals. Although REACH will cost DSM some tens of millions of euros in the next three years, there are also opportunities. DSM is welcoming the new legislation as an important contribution to strengthening the preservation of the environment, as well as a business opportunity, to develop innovative solutions in order to replace hazardous substances. Having that in mind most Business Groups have started dedicated Business Risk Assessments. As always: inconvenience creates opportunities.

All DSM Business Groups will have completed their lists of substances that have to be pre-registered before the deadline of December 1, 2008. The first pre-registrations have been successfully notified at the European Chemical Agency (ECHA) in Helsinki. Before December 1st in total 550 substances will be pre-registered by DSM. Following the pre-registration, substances that are produced over 1000 tons per year and ‘high concern’ substances have to be registered before the end of 2010. Other substances can be registered in later phases, ultimately before 2018.

At this stage a field of concern in the registration phase applies to suppliers, because they have to pre-register the substances in our materials in time. In total this amounts approximately 5000 substances. At 1 July, DSM had assurance about 53% of these. The progress is monitored closely and requires major efforts from DSM Sourcing and BG Purchasing departments.

For enabling the (pre-)registrations a software system, IUCLID5 (International Uniform Chemical Information Database) has been designed and installed in DSM. Besides this system and in order to support the gathering and management of data on use and exposure of substances a Risk Tool is being developed by DSM. This tool, that will be available to all DSM sites worldwide, is linked to the standard DSM system for substances information (WorldWise). The system will be ready in Q4 2008.