It is expected that large companies will not have huge problems to comply with the new regulation but small medium enterprises (SME) will need to re-organize their internal resources and surely to ask for support from external specialized bodies able for: - Chemical Safety Report preparation; - Data bank searches; - Monitoring of committed safety studies (toxicology, ecotoxicology/environmental fate and physico-chemistry); - Support to set testing programmes on the basis of the manufacturing levels and type of substance (intelligent testing); - Economic evaluation of the testing programme in case of consortia participation; - Exposure scenario and Risk Assessment.
In addition, based upon these testing results, the companies offering the chemical substances for sale will indicate acceptable uses through a chemical safety report (CSR) and provide information on the acceptable manner of handling exposure to humans and the environment.
That report said that under the revised draft, downstream users of chemicals will not be required to register their products at all, and importers will have to register their articles only if a chemical is both classified as dangerous and intended to be released in the product; that the transparency of the registry database has been obscured by a provision of automatic anonymity for the registering company; that polymers are almost entirely exempt; and that below a production level of 10 metric tons per year, no chemical safety reports will be required.
Eighty-five million Americans live, work and play within a five-mile radius of 66,000 facilities handling regulated amounts of high-hazard chemicals," according to a March 1999 Y2K and chemical safety report from the CBS.
This was divided into 12 elements that provided a step-by-step guide to registration, starting with inventory development, pre-registration, SIEF's and consortia, to supply chain communications, then moving rapidly on to data gathering, hazard evaluation, development of the registration dossier, chemical safety report and safety data sheet before arriving at dossier submission as the final step.
Pigment producers and importers will want to avoid the expense of having to draw up chemical safety reports (CSRs) on their products, which will have to be attached to the safety data sheets.
