In their latest ECHA Report, the authors criticize the poor quality of registration dossiers. Only one of every three documents reflects the current state of information on the use of and exposure to specific substances. Updates usually occur only under pressure from authorities.
In a conversation with the online portal ChemicalWatch, the deputy executive director of the ECHA, Jukka Malm, argued for a solution that does not impose any new burdens on companies, but simply clarifies existing law.
In fact, Article 22 of Reach obligates registrants to update their dossiers upon their own initiative and “without undue delay“ when new information becomes available and to transmit the revised dossier to the agency. Malm believes it would be better to define a concrete period of time rather than use the current vague formulation.
Nevertheless, the ECHA continues to appeal to the initiative of companies. According to Malm, firms should view their obligation to update dossiers as an opportunity, not a burden. He knows of cases in which a substance was considered for possible inclusion in the authorisation list. Yet, the ECHA dropped the require because more up-to-date data indicated limited usage of the substance.
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