The Chemical Business Association (CBA) has called for the European Chemicals Agency (ECHA) to reveal details of its back-up submission procedure for Reach pre-registration, announced on 18 November.
Peter Newport, director of CBA, said: 'The fact that ECHA has developed a back-up plan to ensure companies can pre-register their substances before the 1 December deadline is good news for industry.
'It is also to ECHA's credit that it has listened to industry's concerns about the relative failure of its Reach IT system and its impact on smaller firms that are going to extraordinary lengths to fulfil the pre-registration requirements.' ECHA's back-up plan provides an additional pre-registration submission method for the final days of pre-registration but says the method should only be used if absolutely necessary.
Newport added: 'ECHA appears to be dealing with industry on a 'need to know' basis.
'Having a contingency plan is all well and good, but further information needs to be made public if this plan is going to operate effectively in the event of a last minute pre-registration stampede caused by further failures of the Reach IT system.' CBA is calling on ECHA to provide answers to several key questions: *With only ten days to go before the end of the pre-registration period, when precisely do the 'final days of pre-registration' begin? *ECHA says that its back-up procedure 'could be applied if Reach IT was not able to absorb the influx of last minute pre-registrations and was not accessible during the final phase of pre-registration'.
Does this mean that any further failure of Reach IT will trigger the back-up plan? *How will industry be advised that the back-up plan has been invoked? *The back-up plan involves an alternative web-based procedure with pre-registrations being submitted by e-mail.
Is ECHA convinced that its e-mail servers and bandwidth has the capacity to cope with the likely demand without further technical failure? *Will this web-based system allow for bulk pre-registrations, an approach used by 70 per cent of all pre-registrations to date? Newport added: 'Industry - and particularly smaller firms - will continue to work evenings and nights to use the Reach IT pre-registration system.
'However, ECHA really must disclose further details of its contingency plans if it is to compensate for the persistent failure of Reach IT.
'Industry cannot be expected to second guess ECHA's intentions.
'The date, time and the conditions necessary for ECHA's back-up plan to be activated must be made clear.
'This is becoming more relevant given the fact that pre-registrations over the past few days have more than doubled from 26,562 (13 November) to 63,107 (18 November).'
