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New Year...New and Continued Regulatory Challenges

04 01 10 - 20:53 2010 will be a year filled with regulatory challenges in chemical compliance both in the US and elsewhere.  Most notibly, re-registration work will accelerate and will be required for the EU under its new REACh chemical notificaiton system.  Additionally, there are anticipated changes to TSCA in the US and with the implementation of the GHS hazard communication requirements globally.

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REACh:  Re-registration of pre-registered chemicals under the EU's new REACh notification system must be registered by December 1, 2010 for those chemicals manufactured or imported into the EU at volumes of 1000 metric tons or more.  Also included in this are chemicals deemed to be carcinogenic, mutagenic or reproductively toxic (CMR) at 100 metric tons or more per year and environmentally toxic substances at 1 metric ton or more.  This is the first deadline for re-registrations under the new law.  Keep in mind that SIEF's (Substance Information Exchange Forums) are formed between companies which intend to re-register the same substance.  It is the company's responsibility to determine when and if a SIEF should be formed.  There can be only one Lead Registrant and one "joint submission dossier" for a given substance.

TSCA:  The chemical registration system in the US, known as the Toxic Substances Control Act (TSCA), will likely see some changes in 2010.  Administrator Lisa P. Jackson is committed to to strengthen and reform chemical management in the US.  The agency is finally recognizing that the 1976 law is both outdated and in need of reform.  A few actions that may be noticed during the year involve using existing tools to legislate and control chemicals of concern, possibly "re-setting" the TSCA inventory and the rolling out of a new electronic notification system for TSCA notices.  There may also be a push to totally re-write TSCA, possibly in a similar fashion to the EU's REACh...but it's still anyone's guess as to how this will all play out.

GHS:  The implementation of the UN's Global Harmonized System of Classification and Labeling (GHS) will finally come into being in the European Union and likely to also become legislated in the US and Canada.  US OSHA will be holding informal public hearings regarding changes to the hazard communication standard during the first 2 quarters of 2010 and Canada's WHMIS anticipates regulation changes during the year.  Implementation status in other countries can be found at http://www.unece.org/trans/danger/publi/ghs/implementation_e.html.

Of course, the landscape for chemical compliance is an ever-changing one and there will likely be more significant changes as the year progresses.