think something is particularly SIEF formation have expressed process moving – it is not set in
unfair on you, voice your opinion concern that some members of a stone or legally binding. If you
within the SIEF. If you still feel pre-SIEF may hold up progress miss the deadline assigned by
you’re being treated unjustly, due to delays in responding or the volunteer facilitator it does
consider taking legal advice (we because they need to refer to not mean you cannot register.
can help you find some through legal departments that need to
our Matchmaker programme). review all the fine details. The SIEF collaboration
Some facilitators are asking worry is that slow starts may Many SIEFs are being formed
those signing up to be prepared mean dossiers not being ready around the basis of a dedicated
to receive and pay an invoice; for Registration. IT system. There are a number of
in most case, this is not a direct It has become practice online systems and standalone
threat to charge, but is based so far for many potential software management tools.
on the fact that when sharing facilitators to put a, perhaps Each need to be considered on
data, those making use of data somewhat arbitrary, time limit their own merit and, although
available through the SIEF will on response to initial letters and you cannot be forced to sign up
need to pay their share before questionnaires. In most cases, a to any of these services, there
registration. The amount is often lack of response suggests that may be a chance to save time
impossible to estimate at the the pre-SIEF member does not and money. Again, if you and
early stage of SIEF formation. want to play an active part in the your SIEF need guidance, our
SIEF or its agreement. However, Matchmaker programme can
Time pressure remember that this is simply a help – just contact the Helpdesk
Many of you who have contacted method many facilitators are at enquiries@reachready.co.uk.
the Helpdesk recently about using to get the SIEF formation
REACH enforcement:
REACH in their day-to-day
business.
the UK’s approach
But what if it goes wrong?
The powers available to
Just who will be policing less aware of how traders and
inspectors are considerable;
REACH, and what are the importers do business. The rest
they can enter premises
penalties for failing to comply of REACH (especially Annex
(including home offices) examine
with the Regulation? XVII restrictions) will be dealt
documents, take samples and
The enforcement of REACH with by whichever agency deals
prohibit activity. And they can
is a matter for Member States, with your occupational health
prosecute companies and
and national legislation must and safety or environmental
individuals. In the worst case
provide a regime of inspection issues, with an enhanced role
there could be an unlimited fine
with suitable penalties. This task for the Environment Agency and
and up to two years in prison.
should have been completed its Scottish equivalent. Other “The powers
So the message is: if you have
by 1 December 2008 but only agencies (e.g. Customs) don’t available to
a problem, get advice and an
around half of the Member have a formal role in REACH inspectors is
action plan. We may recommend
States had done so by then – we but can be asked to assist. considerable; they
you speak to HSE in some
would not dream of commenting More detail is on HSE’s REACH can enter premises…
cases. If you do, we are confident
on this! The situation is website: www.hse.gov.uk/reach/ examine documents,
you will be treated with respect
developing across Europe and enforcement.htm. take samples and
by experts who are there to help
will update you through the web prohibit activity.”
not hinder.
site and future issues of the So how will HSE deal with
REACHReady Review as we you?
learn more. In the meantime, HSE has a tradition of achieving
here’s a quick look at how the compliance by a range of
UK’s Competent Authority is actions choosing, on the basis
policing REACH. of risk, the appropriate approach
in the circumstances. So it’s
UK enforcement unlikely you will be marched off
In the UK the arrangements to court with no warning for a
were in place in time. Put paper-based offence. And the
very simply, enforcement of good news is that feedback
registration and the main supply to REACHReady signals a
chain duties falls to the Health pragmatic and constructive
and Safety Executive (HSE). approach is being taken. As well
So you are dealing with an as having a core team of experts,
organisation that’s familiar with HSE has specially trained all
the chemical industry – but is inspectors who may deal with
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