2009 Reference document - Solvay

3 Rhodia’s
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Responsibilities and Sustainable Development
commitments with respect to the environment
Internal organization to comply with the
REACH regulation
In early 2008, Rhodia implemented a worldwide “project”
organization to create a working network between RHODIA
Enterprises (“Product Stewardship”, business and industrial team),
shared Support Functions (Information System, Legal, Purchasing,
R&D, Finance, Industrial-DRC/HSE) and the team of Experts in
Toxicology, Eco-toxicology and Regulations of DRC.
This project is monitored by:
1 a monthly Steering Committee Meeting bringing together
Business Unit/REACH leaders and Support Functions;
1 a quarterly meeting of Corporate Managers and Support Functions
that determines:
− the policy, rules (for example, capitalization of expenses) and the
long-term vision, and
− the implementation of REACH within Rhodia, specifically in terms
of costs and resources.
In 2008, progress with the REACH project was marked by:
1 the continuation of the inventory of substances subject to preregistration
and implementation of tracking tools for substances
produced and imported by Rhodia in Europe;
1 the continuation of the REACH action plan with Rhodia’s raw
materials suppliers in order to ensure pre-registration of these
substances;
1 the installation of IT tools (IUCLID5, REACH IT, etc.) developed
by the Helsinki-based European Chemicals Agency (ECHA);
1 the evaluation of the “strictly controlled conditions” status of
intermediates isolated from the first tonnage band (subject to
registration by December 1, 2010). These evaluations show, on
(24) Supply Chain includes supply, production and logistics.
Reference Document Rhodia 2009
the one hand, that the production and use of these intermediates
are controlled thanks to an HSE management system and, on
the other hand, that health and environmental exposures are
controlled by Rhodia; and
1 the pre-registration of all the substances manufactured or
imported by Rhodia and contained in the products that Rhodia
puts on the market in the European Economic Area, i.e. a total
of 736 substances that it expects to register.
The year 2009 was again marked by intense activity, including
specifically:
1 the continuation of the “strictly controlled conditions” status
evaluation of intermediates isolated from the first tonnage band
(subject to registration by December 1, 2010);
1 participation in consortia or SIEFs (jointly with other producers
and importers of identical substances) in order to exchange
data and prepare for the registration of substances from the first
tonnage band (subject to registration by December 1, 2010);
1 the identification of Rhodia product uses and customer exposures
in order to prepare the risk evaluation stage (exposure scenarios,
Chemical Safety Report) and communication in the supply
chain (24) ; at the same time, Rhodia also identified its raw materials
uses in order to inform its suppliers by December 1, 2009 for
substances in the first tonnage band to be sure that its uses are
taken into account in their registration files;
1 the preparation of Classification, Labeling and Packaging
Sheets under GHS and the CLP regulation. In order to facilitate
the deployment of the GHS system within the Group and the
implementation of CLP, the DRC has developed informationsharing
tools and a worldwide project group in order to prevent
regions from producing contradictory classifications between
countries for one same product;
1 the registration of the first substances.