SIEF - formation
For all (pre)SIEF communications, please contact us
To all pre-registrants of Cadmium related substances included in our portfolio,
Pre-SIEFs, SIEFs and Cadmium Consortium
For each of the substances declared in the scope of work of the Cadmium Consortium, the Consortium’s Secretariat is prepared to:
- Ease the contacts of the pre-SIEF members debating on the sameness of the substance and to ease the actual formation of the SIEF.
- Support the candidates “Lead Registrant” in their obligations and to act as the “SIEF Facilitator” for the purposes of preparing and submitting the Registration Dossier, and where agreed the Chemical Safety Report (CSR), pursuant to REACH Article 11.
The Cadmium Consortium was formed on 1 July 2007 for the sole purpose of assisting industry to comply with REACH. It is an initiative of the International Cadmium Association. The Consortium is comprised of the major EU manufacturers, major non-EU manufacturers, EU importers and traders, and their respective Affiliates.
The current 25 members of the Cadmium Consortium (~50 legal entities) are focusing on generating and compiling necessary data for 9 Registration Dossiers. The Cadmium Consortium has already dedicated substantial financial and personnel resources to this effort, and is advancing well in this respect. Its members are committed to achieving submission of the Registration Dossier for all substances in the scope of work of this consortium before the first registration deadline of 1 December 2010.
The Consortium is undertaking to compile and assess all relevant existing studies and data necessary to prepare the corresponding Registration Dossiers. We will, as SIEF facilitator, collect information from the SIEF members as well as from sources outside the SIEF.
The Cadmium Consortium has already conducted thorough data gap analyses, and is working to generate data to fill the gaps where appropriate. We are also working:
- to translate all available information from former R.A.’s in IUCLID V format
- to develop read-across approaches,
- to develop hazard classification and labelling proposals,
- to identify and evaluate downstream uses (and exposure scenarios),
- to prepare the CSRs.
The International Zinc Association (IZA) and its staff is contractually providing human resources and administrative support, together with the International Cadmium Association (ICdA) to the Cadmium Consortium to coordinate these efforts. Finally, the Consortium Secretariat is well versed in the SIEF obligations, and has been developing strategies and systems to manage the SIEF process.
Access to the Registration Dossier
For each of the substances declared in the scope of work of the Cadmium Consortium, the Consortium, acting as secretariat of the SIEF, will ensure that all SIEF members intending to register under REACH have timely access to the Registration Dossier for that substance to enable them to register with ECHA by the earliest deadline. In complying with REACH, we are seeking to balance sound science with responsible resource management. We are committed to make available access to the Registration Dossier on fair, reasonable and non-discriminatory terms. Interested companies will have two basic options to obtain the necessary access to information:
· Companies that plan to register and wish to provide resources and expertise to contribute to the development of the Registration Dossier are encouraged to join the Consortium. This will provide companies fullaccess to all information and data developed by the Consortium.It is expected that joining the Consortium will be the most cost effective option for the active participants and companies.
· SIEF members that do not wish to join the Consortium will be able to obtain the Registration Dossier via a Letter of Access (LoA). The Consortium members –in their General Assembly of September 30th 2009- decided on the cost for such LoAs, i.e. for access of companies intending to register that substance. It has been established on a fair, reasonable and non-discriminatory basis, including all of the costs (including administrative and scientific) associated with the preparation of the necessary information.
a. All pre-registrants that have previously indicate their intention to register a substance that is in the scope of the Cadmium Consortium (status PASSIVE, or INVOLVED, or ACTIVE) will be contacted soon in order to:
- Ask for the confirmation on the sameness of the substance
- Ask for the confirmation of the proposed Lead Registrant
- Communicate about the” letter-of-access” –LoA- principles and prices
- Ask for the confirmation of the classification basis
- Communicate about the current identified list of uses
- Communicate the intended planning for the next 8-9 months.
b. The Consortium’s secretariat will welcome any request:
- Concerning the option to join the Consortium
- Concerning the option to not join the Consortium, to remain in the SIEF and fulfil the REACH Registration obligations by means of a letter of Access to the Registration Dossier (LoA)
With Kind regards,
The Cadmium Consortium secretariat
Disclaimer: The Cadmium consortium and IZA do not accept any liability whatsoever with regard to the content, accuracy or use of information contained is this document. The information it contains does not constitute any legal advice.