REACH Co-registrant contracts on vacation?


As the leading and – probably at this time – only provider of a paperless online contracts exchange system for REACH Registrants and Co-Registrants, I am surprised and a little bemused by the lack of people actually requesting contracts in order for SIEF members to co-register for the 2010 deadline. 

With REACHsuite hosting some of the major substances in chemistry which are now registered, there seems to be no great rush on the part of co-registrants to request contracts which provide them with the means to access the deliverables (Letter of Access, token, etc) for them to undertake their own registrations. 

I’m guessing that a lot of Europe is still on vacation. Certainly many of my European contacts seem to be away, and that the prospect of forking out several thousand Euros per letter of access is not exactly making them want to rush back and sign up. 

And this is set against the context where, for certain substances, consortia executives have determined that the cost of Letters of Access will actually rise after the 2010 deadline - they don’t reduce just because you are registering for a lower tonnage band. 

So, as is ever the case with deadline-driven activity, I am predicting a surge of contract requests across our managed substances – totalling 1176 now - from late September through to the November 30th deadline date. 

This is a pretty risky strategy when, for many companies, that Letter of Access is their licence to operate. But then I guess its human nature to put off regulatory matters that cost until the absolute deadline. 

However with too many having previously left pre-registration to the last minute, the enormous underestimation of the time and processes involved may see many face delays on the difficult path to successful Registration. 

Only time will tell. And as it stands time is the one thing that these Co-registrants haven’t got. 

Malcolm Pollard, Baytouch

Malcolm Pollard

MALCOLM Pollard, managing director of Baytouch Limited, has more than 15 years experience of producing software to support regulatory affairs that meets the requirements of the chemical industry. In 2006, he had the vision to steer Baytouch towards developing a software solution that would meet the needs of companies needing to comply with the, as then, draft REACH regulation. Baytouch's success in providing REACH IT solutions is based on its comprehensive understanding of the Regulation, its innovation and the ability to adapt to changing REACH requirements which has resulted in its REACHsuite becoming the leading commercial REACH IT solution for consortium and SIEF management.