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Six manufacturers of sodium chlorate (Akzo Nobel, Arkema, Ecros, Electroquímica de Hernani, Kemira and Solvay ) have set up the sodium dichromate authorisation consortium to authorize their downstream use of sodium dichromate as a processing aid in the sodium chlorate process.
Ingrid Brassart, chairperson of the authorisation consortium from Akzo Nobel:
“ReachCentrum was selected first as the consortium secretariat based on its experience with consortia management, more particular relating to in financial and communication aspects but also due to their knowledge of REACH authorisation process as such. During the preparation for application ReachCentrum has proven to be very supportive in translating between the language of pure technical service providers and the understanding of our group. Also in reviewing documents for the application, ReachCentrum’s input is very helpful.”
The Lead registrant and a company specialized in the production and marketing of foaming agent formulations have taken action in setting up an ad-hoc taskforce due to the speedy and unexpected entry of ADCA into the authorisation scheme. The Asian manufacturers were not aligned to answer to this kind of regulatory process and their European downstream industries were largely not prepared for it. Representatives of both groups recognizing the urgency and wanting to have a more direct involvement was the main reason why the Taskforce joining all parties was set up.
ReachCentrum was approached in March 2013, the taskforce held its kick-off meeting in May and has meanwhile over 50 members. A first milestone was the submission of a consolidated and technical input to the public consultation on prioritization in September 2013 and the following awareness raising amongst member states.
ReachCentrum was selected by the founders due to its long experience in managing consortium and its close relation with Cefic and authorities. The Taskforce management as well as advocacy abilities were appreciated during the selection process.
Role of ReachCentrum
Next to managing the Taskforce by taking care of all administrative, financial and communication issues as well as organizing the meetings not only formally but also content-wise , ReachCentrum is also leading the technical issues by contacting and contracting the technical experts necessary. Last but not least organizing ReachCentrum is playing a major role when it comes to coordinating the awareness raising in member States, the EU Commission and aligning with other involved sectorial associations.
Eight founding members of the HBCDD in EPS consortium submitted successfully a joint Application for Authorisation. The eight submitting members of the consortium, set-up at the beginning of 2013 are: Ineos Styrenics, Monotez S.A., StyroChem Finland Oy, Sunpor Kunststoff GmbH Austria, Synbra Technology B.V., Synthos S.A., Unipol Holland B.V. and Versalis S.p.A. These companies submitted jointly 13 applications for two uses.
The consortium’s aim is to obtain a bridging authorisation for the continued safe use of HBCDD in EPS, until an identified alternative is commercially available in adequate quantities, together with the necessary technical and certification approvals. This is to allow sufficient time for a smooth transition away from HBCDD without market disturbance.
ReachCentrum offered a “one stop shop” approach together with the Technical Service Providers Peter Fisk Associates Ltd. and eftec. ReachCentrum was selected based on its well recognized experience with consortium management, financial administration and communication. The technical service providers brought historical knowledge on REACH and HBCDD to the members as well as an understanding of structure and content for Authorisation dossiers.
Role of ReachCentrum
In addition to managing the consortium and taking care for all financial administration, ReachCentrum was the focal point in the contact between ECHA and the members of the consortium. ReachCentrum was also the “Trustee” for the members. The role as “Trustee” was of added value in making the decision half-way of the dossier preparation to go for a “Joint Application”.
Once the documents for the AfA were finalized and ready for submission, ReachCentrum did the actual submission on behalf of the Lead Applicant and the 12 other co-applicants. The actual submission of the Application was done in close cooperation with ECHA to ensure a successful process. The Application of the HBCDD dossier was the first Joint Application received by ECHA.