Inspections? Don’t panic!

Be prepared for ASL inspections: TEAM mastery offers compliance audits for the REACH and CLP Regulations, and more.

On 31 May 2018, Regulation (EC) No. 1907/2006 (REACH) entered fully into force: at this stage, it is crucial for companies to verify their level of compliance with the provisions of the Regulation, whether they are manufacturers/importers or Downstream Users of chemical substances. Additionally, it is important to consider that competent authorities have expanded their inspection targets, so it is essential for companies to be ready in the event of an inspection.

THE PROPOSAL

TEAM mastery’s Product Safety division is available to carry out compliance audits for the REACH Regulation, alongside the verification of obligations related to the CLP Regulation, in all its complex requirements.

The audit program essentially follows the guidelines for REACH & CLP inspections issued by Regione Lombardia, integrated with the targets set for 2018 within the REF-6 project prepared by the European Chemicals Agency (ECHA).

DETAILS OF THE ACTIVITY

The activity would be structured into two separate parts: one onsite at the company, involving the inspection of documentation and work areas; the other conducted at the office, dedicated to drafting a report on the onsite assessment and the company’s regulatory compliance status, including indications of any critical issues and/or necessary actions.

The purpose of the audit activity is to verify:

  • the submission of the registration or, for substances under transitional arrangements, the pre-registration or inquiry;
  • the existence and effectiveness of a management and control system for substances, mixtures, and articles;
  • the presence and compliance of SDSs with Article 31 of the REACH Regulation;
  • the presence, where required, of technical annexes to the SDS with summaries of exposure scenarios;
  • compliance with the identified uses and related precautions, as well as exposure control measures, as outlined in the relevant SDS subsections;
  • the suitability and adequacy of personal protective equipment for the identified uses of substances or mixtures;
  • the communication along the supply chain;
  • the correct classification, labelling, and packaging of hazardous substances and mixtures according to the CLP Regulation and Legislative Decree 65/2003;
  • the submission of notifications as required by Articles 40 and 49 of the CLP Regulation.

KNOWING YOUR SUBSTANCES, BEYOND REACH

Following the last REACH deadline, many of the substances currently in use have undergone registration and, in some cases, have been found to have intrinsic hazardous properties. As a result, specific authorisation or restriction procedures may be established and required where risks to human health and the environment are not adequately controlled. Therefore, it is important to stay informed about the evaluation status of your substances, to promptly identify critical issues and implement alternative solutions, ensuring continued market presence.

BIOCIDES AND PPP: NEW HORIZONS

In addition to the activities mentioned above, which are strictly related to the REACH and CLP frameworks, we are also available to offer support services in the field of new regulations on biocidal products and plant protection products. The goal is to assist companies in identifying regulatory obligations and deadlines to ensure continued commercial competitiveness.