PREVIEW OF THE BACK-UP SUBMISSION PROCEDURE FOR PRE-REGISTRATION

https://www.chemnet.com   Nov 26,2008

　　In the news alert of 18 November 2008 ECHA announced that it had developed a back-up procedure for pre-registration. The procedure would be enabled if REACH-IT is unable to process the very large number of submissions expected by the deadline of 1st December. This alert provides more detail. If the procedure is to be enabled, a further news alert will be published.

　　REACH-IT performance

　　The REACH-IT system has handled an extremely large number of pre-registrations–greatly in excess of the original design capacity. ECHA carefully monitors the performance of REACH-IT alongside the number of pre-registrations received and other activities in the system. ECHA has concluded that, should activity in REACH-IT increase at the present rate, there is a risk that response times would become very slow and all users willing to enter the system might not be able to do so during the peak hours. Companies can help avoid the overloading of the system by using REACH_IT outside peak hours, when the load on the system is lower. They should also only enter REACH-IT when they wish to pre-register or obtain submission reports. In addition they should not try to run automated scripts in REACHIT (ECHA will block the IP addresses of users who try such scripts and may also take additional measures against them

　　The alternative procedure

　　To ensure that companies can continue to pre-register in the event of problems with REACHIT, ECHA developed an alternative procedure, based on a web form, which will allow companies to pre-register outside the REACH-IT system. ECHA wishes to emphasise that the form will not have the full range of functions of REACH-IT (for example. generation of pre-registration numbers and search facilities for SIEF members) and may take some time for ECHA to transfer the information submitted into the REACH-IT database. Consequently, ECHA will only enable the procedure if the Agency is no longer confident that REACH-IT can process all submissions by the deadline, i.e. midnight of 1 December GMT. The news alert of 18 November 2008 explained the consequences of the alternative route and how those who submitted via that route will obtain pre-registration numbers after 1 December

　　If a company uses the alternative procedure, the fastest and surest way to pre-register substances with EC numbers is to use a bulk file in an XML format compatible with REACHIT, which can directly be attached to the web form. Further information is provided in Attachment 1.

　　If a company using the alternative procedure wishes to pre-register only a limited number of substances or wants to pre-register substances without EC numbers, they will be able to fill in a spreadsheet, available on the pre-registration web form page, with information on their substances. For each substance they will need to provide a substance name (preferably in the IUPAC nomenclature) and where possible an EINECS number, or a CAS number and CAS name. Further information is provided in Attachment 2.

　　Before a company uses the pre-registration web form, they should try to ensure that they have previously signed up in REACH-IT and obtained a user ID. However, if that is not possible, they must fill in a spreadsheet, available on the pre-registration web form page, with their company details. Further information is provided in Attachment1 and 2.

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