REACH

One consequence of scientific and industrial development is that the amount of products manufactured globally has significantly increased, a consequence of which is that we come into contact with more and more chemicals in our everyday lives.

Since, so far, this has not been the case with regard to more than 100,000 chemicals available in the European marketplace, new legislation on chemicals has been particularly focused on the principles involved – precaution, adequate information and substitution.

This new chemical legislation, commonly known as “REACH”, has been in force since 1st June, 2007. Under the European Union’s REACH regulation, companies are required to provide hazard data, use and exposure information, conduct risk assessments and take risk mitigation measures for chemicals used in commerce or imported into the European Union by a specified deadline depending on their hazard and volume. The overall aim of REACH is to improve the protection of human health and the environment whilst maintaining the competitiveness and enhancing the innovative capability of the EU chemicals industry. This legislation transfers the responsibility for safety in the handling of chemicals to the chemicals industry. Fundamental MOL Group principles, its commitment to product stewardship and its basic understanding of the health, safety and environmental aspects of products throughout the entire life cycle are all in line with REACH’s goal of improving the protection of health and the environment, in every aspect.

MOL Group launched preparations for meeting the requirements of the new legislation at the beginning of 2006, coordinated by its HSE (Health, Safety & Environment Protection) organization. Its main tasks were: Impact assessment & opportunity identification; searching for alternative substances; communication with all stakeholders concerned.

In 2008 we identified all those substances used at MOL Group which fall under the scope of REACH and successfully pre-registered them by the given deadline.
In 2009 the main issue was to collect all the data on our products necessary to comply with REACH regulation and identify the relevant SIEFs and Consortia.
In 2010, MOL Group submitted 165 substance registration dossiers to ECHA. The figures include the number for INA as well because MOL Plc. submitted INA’s registration dossier based on the only representative Agreement. MOL Group registered all the non-REACH relevant substances by the given deadline (3rd of January, 2011.) via REACH IT to the European Chemical Agency.
During preparatory work for REACH, and during preparation of registration dossiers, we received major support from one of the members of the contracted consortium, ‘Concawe’, the oil companies’ European Association for Environment, Health and Safety. MOL Group had already joined other consortia and the European Chemical Industry Council (CEFIC).

MOL’s communication is continuous within the supply chain. We keep contact with our suppliers about their registered substances and their uses and inform our customers about our registered substances and their uses. We have collected the relevant intermediates - so called Strictly Controlled Condition - declaration as well.
MOL Group on an individual legal entity level is working on completing Safety Data Sheets (SDS) and completing substance Exposure Scenarios to inform our customers more deeply about the impacts of our substances from a Health, Safety and Environmental point of view.
MOL Group has developed a company-level information system which provides the background support for REACH and Product Stewardship related issues. The new software includes a substance inventory management system which is the basis of all REACH relevant data. The software supports the generation of the SDSs in all necessary languages. The development of interfaces between different ERP systems and the supporting software has already started.
In 2011, after the first registration deadline MOL Group should have updated the Safety data sheets due to the registration dossiers content and started to deal their translations to the customer languages. MOL R&M submitted one new registration and one another is still ongoing. Several classifications were done based on new CLP (Classification, labelling and Packaging) inventory. SVHC (Substance of Very High Concerned materials) list is continuously checked to ensure our legal compliance. We have passed every checking by the local authorities.

In 2012 the main tasks will be to prepare for the next registration deadline in 2013 (6 substances), to continue the translation work, to update the SDS and to generate the ES (Exposure scenarios).