Preparing for Inspection under REACH and CLP

The European Chemicals Agency is charged with managing REACH across the EU but each Member State (MS) has legislated for enforcement and penalties. It is important to understand who is responsible for what and how enforcement is co-ordinated across all MS. We will look at:

• Roles & responsibilities of regulators
• Joint enforcement projects
• Penalties & prosecutions
• The impact of the New EU Regulation on Market Surveillance and Product Compliance

The reality is that 100% REACH / CLP compliance is difficult to attain, however in order to approach an inspection with confidence you need to feel that you have a handle on your risks of non-compliance and how to mitigate against them. Your business activities determine your roles under REACH and CLP and they in turn determine where your main risks lie.

Working in groups, attendees are invited to think about how the role of the company and its activities under REACH / CLP will determine the key risk areas for non-compliance.

Inspections may be initiated for a range of reasons and understanding the reasons helps provide focus for the preparation. 

Inspectors may look at any aspect of the regulation they choose but the focus is likely to be driven by company activity, its track record and aspects most likely to impact on safe chemical. We will explore: 

• What is the likelihood of an inspection?
• When will I be inspected?
• Who will carry out the inspection?
• What will be inspected?
• What form will the inspection take?
• What are the possible consequences?

The growing number and complexity of regulations and the push for operational transparency, means that organisations are increasingly seeking comprehensive means for compliance control. We will explore how businesses can make that transition from imposed regulation to proactive ‘risk’ management through the development of an Integrated Management System (IMS). The aim of an IMs is not only to minimise risk, but also to maximise opportunities.

Again working in groups, attendees will take part in an activity which will help them to use the identified risks from the previous exercise, and broaden this out to include risks to stakeholder relationships, human health and the environment. We will then learn how we can evaluate these risks using a risk matrix and identify controls.

We will explore:

• ISO-Compliant Management Systems and integration models
• The Role of ISO 19600
• Risk Management as an underlying concept
• Stakeholder prioritisation
• SWOT and PEST analysis
• The risk evaluation process
• Measuring and monitoring compliance
• Automating monitoring efforts

Good preparation is the key to a successful inspection and this starts with a commitment to compliance and an ability to demonstrate that commitment. In this last session we will consolidate the material covered throughout the day, and finish off the workshop by exploring how to:

•  Put together checklists to prepare for an inspection
• Gather documentation to support the inspection on the day