ECHA has published several practical examples to help you comply with REACH 2018 by the May 31 deadline. Most of these examples are in the form of PDFs available in a number of languages. At the same link, there is also a series of video tutorials for the IUCLID software. These may not be practical examples in the sense that the scenarios at that link are, but they do show actual use of the software.
One of the practical examples looks at cost sharing among co-registrants. ECHA requires co-registrant to agree on cost-sharing, and to make sure that the method of cost sharing that they come up with is fair. They don’t offer additional specific guidance on cost-sharing, so the example is helpful in coming up with a plan to share the costs.
First, a reminder of the 8 steps to REACH compliance:
- Step 1: Know your portfolio
- Step 2: Find your co-registrants
- Step 3: Get organized with your co-registrants
- Step 4: Assess hazard and risk
- Step 5: Prepare your registration as a IUCLID dossier
- Step 6: Submit your registration dossier
- Step 7: Keep your registration up-to-date
ECHA’s examples relate to steps one through five on this list. The cost sharing example is relevant to step 3.
The cost-sharing co-registrants
One of ECHA’s examples helps clarify the decision-making process for sharing costs. In this example, seven companies are using data from a study owned by one of the companies. That company — call it ACME — spent 200,000 euros on the study. ACME can prove this because they have invoices from a laboratory and a consultant, plus internal records showing the amount of time spent in-house. All the co-registrants agreed to the hourly cost of the work done in-house.
In fact, many companies don’t have the invoices or the hours of in-house work readily available. If your company doesn’t have this data, ECHA suggests that you and your co-registrants figure out what it would cost to redo the tests, and calculate the appropriate costs from the year the testing was completed.
Once the co-registrants agree to ACME’s claim of its investment in the test, they discuss the factors that affect their share of the cost. In this case, for example, the co-registrants agree that ACME will continue to own the data and that it will not be used for any purpose except REACH 2018 dossiers. Since each company is paying for the right to use the data, not for shared ownership of it, they agreed to a reduced price.
They could have taken inflation into account, but since some of the companies are located in countries which experienced deflation, they agreed not to consider this factor.
Once the companies have agreed to the cost-sharing, it will be important to keep a record of the agreement, and also to keep track of the payments as they are made to ACME.
Cost sharing tools
It’s obvious from this example that record-keeping is extremely important for REACH 2018 cost sharing. Tools that help you keep all the documents and discussions for your chemical regulatory compliance project together will help keep costs in line.
They also reduce stress and improve collaboration.
Schedule a demo of EUPHOR, our chemical regulation compliance project management software. See how it helps control costs and keep any chemical regulation compliance project on track.