REACH: How to prepare for the inspection?

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Courtesy of Selerant srl

Inspections REACH: what are they?

With the publication of Decree Sanctions (Legislative Decree no. 133/2009, published in the Official Gazette of 24/09/2009 ) which provides for the application of penalties in cases of non-compliance with the provisions of the REACH Regulation, began an intense program monitoring and verification by the competent authority (Ministry of Health). 

Inspections REACH, according with the State-Regions, may take place without notice in the companies, but the Ministry of Health has prepared a questionnaire “Summary sheet inspections”, which anticipates undertaking any inspection. 

The questionnaire has only the aim to gather information on the type of business the company and the position of this respect to REACH. The reception of the questionnaire does not necessarily imply that the Company will be subject to Inspections.

How can companies get prepared for REACH inspections?

To get prepared for REACH inspections, companies should have carried out the following actions:

  • 1. Preparation of safety datasheets updated and freely available by workers and staff RLS;
  • 2. Use substances/mixtures in a manner consistent with the provisions of the producer, through proper implementation of risk management measures reported at the various exposure scenarios provided by the manufacturer; 
  • 3. Observe any restrictions contained in safety datasheets due to the presence of particularly hazardous substances (SVHC- of Very High Concern).
  • 4. Verification of authorization from the supplier to the production of specific substances; 
  • 5. Buy substances / mixtures which comply with the REACH legislation. It is therefore recommended to always ask for a statement from the supplier of the registration / preregistration of the substance purchased (to put as contractual clause);
  • 6. Record the successful pre-registration/ registration substances in accordance with the REACH Regulation. 

REACH: What are the sanctions following an inspection?

We remember that the Sanctions Decree as well as prescribe penalties for certain administrative violations of the Rules, Articles 14 and 16, also provides criminal sanctions in the case of placing on the market or use of substances listed in Annexes XIV and XVII (substances subject to authorisation or restrictions). 

It is important that companies do not catch unprepared.

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