ECHA第二次REACH执行项目的结果发布

　2013年9月4日，欧盟ECHA发布了第二次REACH执行项目(REF-2)的结果，其主要集中点集中在下游用户——特别是混合物——对于REACH法规和CLP法规的符合性上。

　　该项行动自2011年5月起至2012年3月。成员国的监管机构核查了1181个企业约6900个物质、4500个混合物和4500份的安全数据清单(SDSs)。被核查的企业多为中小型企业，超过半数的企业拥有多重身份：不光是下游用户而且拥有其他身份，如：制造商、进口商、分销商甚至是唯一代表。

　　结果显示：67%的被调查的企业不符合一条或多条REACH或者CLP的条款。包括：违反REACH法规的注册(预注册)(8%)，通报(CLP法规，15%)、保持数据(20%)和不足的风险管理措施(12%)。

　　仅有3%的企业没有SDSs，但是有52%的被核查的SDSs不完整。为此，核查人员提醒改进SDSs的相关表格。此外，显示93%的工人可从SDSs获得相关信息，但是实际上该数据只能达到79%。

　　总之，该项目的结果显示了在SDSs、通报、注册等方面符合性的可改进的空间。业界可对此提起关注。

　　详情可参考ECHA的新闻。

　　The second enforcement project initiated by ECHA's Enforcement Forum focused on REACH and CLP obligations of downstream users . Of a total of 1 181 companies inspected, 67% did not comply with one or more provisions of these legislations.

　　Helsinki, 4 September 2013 – The ECHA Forum's second enforcement project (REF-2) focused on checking the compliance of downstream users – particularly formulators of mixtures – with the essential requirements of the REACH and CLP regulations. This enforcement project promoted a level playing field through the harmonisation of enforcement approaches in the Member States and fostered cooperation between inspectors. It was carried out in 29 Member States or EEA countries.

　　The project's operational phase was carried out from May 2011 until March 2012. The national enforcement authorities inspected 1 181 enterprises covering 6 900 substances, 4500 mixutres and 4500 safety data sheets (SDSs). The majority of the inspected companies were small or medium-sized. More than half of the inspected companies were not only active as downstream users but also in additional roles, e.g. as manufacturers, importers, distributors and only representatives.

　　In total, 67% of the inspected companies were non-compliant with one or more provisions of REACH or CLP. Non-compliance was most commonly related to contraventions of (pre-)registration (REACH, 8%), notification (CLP, 15%), failure to keep information (20%) and having deficient risk management measures (12%).

　　Only 3% of companies failed to have the SDSs on site. However, 52% of the inspected SDSs showed deficiencies. Despite the high rate of defective SDSs, inspectors noticed an improvement in the formats used and availability of SDSs in comparison to earlier inspections. The findings also showed that 93% of the workers could have access to relevant information from SDSs. However, practice shows that the actual rate was, in fact, lower at 79%.

　　It is clear that the quality of the SDSs and compliance with the notification and registration obligations need to improve. Given the complexity of the new chemicals legislations, industry needs to undergo a learning phase. For that reason, industry should step up its SDS stewardship in order to establish compliance in this area of responsibility. Industry can also find some recommendations in the project report.