REACH IT tools training

Margot MägiValérie Lasseigne-PhrakonkhamDirectorate of Registration European Chemicals Agency

Luxembourg9 April 2018

Agenda

• Overview of REACH IT tools

• From the dossier submission to registration

• REACH-IT main functionalities

• REACH-IT member online submission wizard

• IUCLID 6

• Completeness check and manual verification

• Exercise 1: creating a member dossier in IUCLID cloud

• Read-across in IUCLID

• Chesar in a nutshell

• Exercise 2: submitting a member dossier to REACH-IT

• ECHA support and guidance. DCG solutions.

• Q&A

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The aim of the training today is...

... to get a flavour of all the main IT applications relevant for REACH... to be able to choose the right tools for yourself... not to be afraid for the REACH IT tools... to know where to find help... to ask us questions

IT tools for REACH

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Datapreparation

tools

Data generation

tools

Datasubmission

tool

IT tools for REACH

Data preparation

tools

Data generation

tools

IT tools for REACH

Datasubmission

tool

Data preparation

tools

Data generation

tools

IT tools for REACH

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What application to choose?

From dossier submission to registration

Regulatory processing by the Agency

IUCLID I6Z

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Good to know

Lead submits the registration dossier first

Members can submit as soon as the lead has passed business rules

Members are parked until the lead pays and passes TCC

TCC can take for ECHA up to 3 months after REACH deadline. Outside deadline period it may take up to 21 days

Registrants with pre-registration and submission by 31 May 2018 can continue their import/production with no interruption

New registrants on the marked have to submit an Inquiry dossier first and receive a registration number before import/production

Main functionalities

EU Industry

Representative for EU Importers

EU Member states

REACH

CLP Data(GHS)

REACH-IT aspires to be THE innovative, user-friendly,and only submission tool used by Industry andCompetent Authorities for REACH and CLP data

REACH-IT aims at being the main communication andinformation hub for Industry in relation to submitted data

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Login or create a new company account if you do not have one yet

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REACH-IT home page

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Main menu

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Checklists in wizards

Page help

Topic help

Determine your company size (1/2)

• If you are an SME, you need to update your company size

• Important because it will determine your fees

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Determine your company size (2/2)

• Go through the checklist to understand the company size definition

• Declare company size and upload documentary evidence

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Search and join the JS

• You will see the available joint submissions for the substances you have pre-registered or inquired

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Search and join the JS: launch the wizard

• You need the JS token provided by the lead

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Joint submission page

Create and submit a member registration dossier online in REACH-IT

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Create and submit a member dossier online

• Simplified way to create a member registration dossier directly in REACH-IT

• Pre-filled information and reduced number of fields

• Step-by-step wizard with online help features

• Mandatory information highlighted

• Automatic saving and possibility to update

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Conditions

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Required data

• Same data in IUCLID and in REACH-IT

• Every co-registrant of the joint submission: Substance identity Tonnages of the last 3 years Uses and conditions of use through the life cycle

• Co-registrants 10 tonnes per year or more: Attach chemical safety report, unless agreed with the lead

that he will submit on behalf of the members

• Members who need to submit own classification and labelling

• Possibility to indicate confidentiality claims

How to use the member online wizard

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Start the dossier creation from the joint submission overview in REACH-IT

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Submit online dossier

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Use the integrated help

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First step: Main constituents

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Move to the next step when required data is filled in

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Second step: Substance identification

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Integrated Business rules and TCC rules

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CSR and Guidance on safe use

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Confidentiality claims

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Review your dossier

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Submit in REACH-IT

Follow the submission progress

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Find your registration decision

Creating a complete dossier in IUCLID

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• Go to IUCLID• Create a substance dataset• Fill-in the information

2• Run the Validation Assistant on the dataset• Correct the failures

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• Create the dossier• Run the Validation Assistant on the dossier• In case of failures, correct the dataset or re-create the

dossier

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Download data, e.g. reference substances;

FAQ regarding installation, migration from IUCLID5 to

IUCLID6, etc.Technical manualsSign in and

download theapplication

https://iuclid6.echa.europa.eu/

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Search by UUID

View yourdossiers

Create new or modify your

existing substances here

Store chemical information on particular

chemicals once in the database and link it from

there to any IUCLID section.

Import files: LE, substance datasets, reference substancesValidate the substance

datasets and also the final dossiers in order to minimize the risk

for errors

Estimate thefee

Create a template toreuse same

endpoint datain diferent datasets.

Main functionalities

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View whatinformation willbe publishedon the ECHA

website

Datasets’ list

• Find your dataset from the list of all the substance datasets

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Dataset’s content

• Click on ‘TOC’ to display the table of content of the dataset

• By default, the view is ‘REACH Complete’• Select the relevant view from the black

arrow

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Section tree

• Mandatory sections are marked with a red asterix *

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Data requirements

• Lead data requirements compared to the member data requirements

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Filling-in a dataset

• Right-click on a section to create a new record or a new endpoint summary

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Tips for filling in a dataset 1/2

• Every value must be followed by a unit

• Every ‘other’ must be followed by a justification in the designated free text field

• Every justification must be (scientifically) meaningful

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Tips for filling in a dataset 2/2

• Use free text templates as guideline

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Help needed? Press F1

IUCLID contains an embedded Help System. Press F1 to access it. It contains:

• Information on the IUCLID functionalities• Help text for the IUCLID fields• Dossier preparation manuals, e.g. how to prepare a registration

dossier

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Validation assistant

Creating a complete dossier

1• Create the dataset• Fill-in the information

2• Run the Validation Assistant on the dataset• Correct the failures

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• Create the dossier• Run the Validation Assistant on the dossier• In case of failures, correct the dataset or re-create the

dossier

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Validation assistant (1/7)

• Access the substance datasets list

• Right-click on the dataset which you want to check and select ‘Validate’

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Validation assistant (2/7)

• Select the submission type

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Validation assistant (3/7)

• Provide the dossier header information to get the correct outcome

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Validation assistant (4/7)• Correct all the submission checks: both

business rules (BR) and technicalcompleteness check rules (TCC)

• Quality checks are recommendations to improve the quality and consistency of your data; not subject to completeness check

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Validation assistant (5/7)

• Location of thefailure

• Name of the table

• Number of therow in that table

• Error description

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Validation assistant (6/7)

• Refresh the Validation Assistantreport after correcting a failure. Click Re-check.

• Right-click on a TCC failure to be automatically directed to the error location in IUCLID

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Validation assistant (7/7)

You can (un-)hide the Validation Assistant clicking on this icon

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Dossier creation

Creating a complete dossier

1• Create the dataset• Fill-in the information

2• Run the Validation Assistant on the dataset• Correct the failures

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• Create the dossier• Run the Validation Assistant on the dossier• In case of failures, correct the dataset or re-create

the dossier

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Dossier creation

• Select the dataset

• Right-click and create dossier

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Dossier creation wizard

• Select the correct dossier type

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Dossier creation wizard

• Fill-in the dossier header

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Dossier creation wizard

• Fill-in the dossier header for update

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Open the dossier

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Validate the final dossier

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Export the dossier

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Technical Completeness Check

Technical Completeness Check (TCC)

• The technical completeness check ensures that all the required elements are in the registration dossier as per Article 20(2) of REACH Regulation

• It is performed on each registration dossier submitted to ECHA – both initial and update submissions

• It consists of automated checks that can be replicated by the Validation Assistant and manual checks performed by ECHA staff

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TCC outcome (1/3)

TCC passes:

• Message from ECHA in REACH-IT

• If the payment (if invoice was issued) is received on time, your submission is complete and a positive decision is sent to you via REACH-IT

Initial submission: registration number assigned

Update of existing registration: ECHA will accept the updated information in the database

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Failure of TCC 1st time:

• Letter in the REACH-IT task box

• Both initial submission and update of existing registration:

Only one possibility to submit a complete dossier

Deadline specified in the letter

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TCC outcome (2/3)

Failure of TCC 2nd time:

• Negative decision in the REACH-IT task box, informing that submission is rejected

• Initial submission:

Registration number not granted

Fee is not refunded (if invoice was issued)

• Update of existing registration:

The updated information is not accepted into the ECHA database and subsequent processes

You keep your registration number

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TCC outcome (3/3)

Manual checks at completeness check

• As of 21 June 2016, the automated completeness check was complemented with additional manual checks by ECHA staff of certain elements of the registration dossier that cannot be checked automatically

• Not displayed by the Validation assistant

• Document with information on manual checks area is published on the ECHA website, under Support -> Manuals:

https://echa.europa.eu/manuals

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Areas for manual checks

1. Substance identification (IUPAC name, composition, manufacturing process description of UVCB substances, analytical information)

2. Justification for waiving of standard information requirements (physicochemical, environmental fate and hazard information, toxicological and ecotoxicological information)

3. Testing proposals on vertebrate animals (presence of considerations for adaptation possibilities)

4. Justification for waiving of Chemical safety report.

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Summary

Key points for completeness

• Be clear and transparent

• When providing a justification, always summarise the main points of the justification in the expected field, and if needed refer to a section/field where more details are given – note that reference alone is not enough

• Use the correct field to provide the information

• In case your submission has failed TCC, refer to the letter and read through the failure message in Annex 1 carefully

• To avoid introducing new completeness check failures it is not advisable to update any other parts of the dossier than those listed in Annex 1

• Annex 2 of the communication letter provides technical advice on how to update your dossier

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Tasks in REACH-IT

• In case of technical completeness check failure, you will receive a new Task in REACH-IT

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Additional support (1/2)

• Assign a relevant contact person in REACH-IT

• Make sure

Contact is responsible for the submission

Person can be contacted via phone/email

Your contact details up to date

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Additional support (2/2)

• We may contact you by phone

Remind you the technical completeness check deadline is approaching

Assist you with complex failures

• Summary email always sent after the call

We are here to help you.

Webinars

• Webinar on the completeness check process

Completeness check - preparing a registration dossier that can be successfully submittedApril 2017

REACH 2018 webinar: Completeness check - preparing a dossier and the most common failuresMarch 2018

REACH 2018 questions and answers - everything you want to know about registering successfully19 April 2018, 11:00-12:30 EET (Helsinki time)

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IUCLID Cloud

IUCLID Cloud (1/2)

IUCLID Cloud Trial

IUCLID Cloud for SMEs

• A new platform for delivery of Business Information systems in ECHA• The first service focuses on IUCLID

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IUCLID Cloud (2/2)

• Aimed for SME users to prepare registration dossiers under REACH for 2018 deadline

• Work fully on a web browser without installing anything locally• Automated backup and data recovery in case of data loss• Immediate subscription activation• Up to 1 GB of secure data storage • Target 24/7 availability except for pre-defined maintenance

periods occurring outside the working hours• Controlled service updates with every new release• Facilitate working anywhere (easier remote access) and

delegation to consultants• IUCLID Helpdesk support during office hours• Integrated help and support for dossier preparation

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Support and guidance

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Guidance and Support

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Guidance document

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Registration manual

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Registration manual – IUCLID 6

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Webinars

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REACH 2018 web page

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Contact form

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Useful links

• ECHA website https://echa.europa.eu

• Guidance document https://echa.europa.eu/support/guidance

• Registration manual https://echa.europa.eu/manuals

• Document on manual verification https://echa.europa.eu/manuals

• Webinars https://echa.europa.eu/support/training-material/webinars

• REACH 2018 web page https://echa.europa.eu/reach-2018

• Contact form https://echa.europa.eu/contact

• Follow us on social media: Facebook, LinkedIn REACH 2018, Linkedin, Twitter, YouTube

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