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Enforcement of REACH and CLP is a national responsibility, therefore each EU Member State must ensure that there is an official system of controls and lay down legislation specifying penalties for non-compliance with the provisions of REACH.

The dedicated ECHA webpage is available on the following link ECHA enforcement forum

REACH INTERNAL AUDITS


I n order to minimize the risks of non-conformity regarding REACH and CLP, Syensqo decided to implement a process of internal verification (Compliance Reviews) of REACH in the GBUs and sites.

The Global Product Registration & Compliance team has planned internal compliance review, but can also realise compliance review on demand or provide help and support to prepare inspections from authorities.

The latest, most recent issue of the guidance dedicated to the Management of Compliance review is accessible by the following link :
  • TRIGGERING AND CONDUCTING COMPLIANCE REVIEWS IN ACCORDANCE WITH THE REACH/CLP REGULATIONS / IND-HSE-PRAS-09-GUI-EN - TO BE REVIEW
  • Compliance Review / Reach CLP Audit Manual - TO BE   REVIEW


PLANIFICATION OF AUDITS & REPORTS


The planification of REACH internal audits is available on this Planning 2025
Reports of audits are available here



 

INSPECTIONS FROM NATIONAL AUTHORITIES OF Syensqo SITES


The main thematic of inspections was:

  • Conditions of use of SCC intermediates

  • Status of Legal entity with « only representative (O.R.)» role

  • duty to pre-register/register and the related documentation (submission reports or updates in case, substance quantity tracking, check against one of the dossiers extracted by case)

  • SDS-management for manufactured and purchased substances,

  • purchase organisation regarding supplier REACH declarations,

  • e-SDS compliance check, information of the workers

Since 2009, Syensqo had various inspections :

  • La Rochelle (Oct. 2009/1 observation; Nov. 2010/5 observations)

  • Saint Fons Chimie (Nov. 2009 - 3 observations)

  • Melle (Nov. 2009 - 1 observation; Dec 2011 – 1 observation - Feb 2017)

  • Clamecy (Dec. 2009 - no observation; June 2016)

  • Ospiate (April 2010 - no observation)

  • Chalampé (Nov. 2011 – no observation; March 2016 - no observations)

  • Syensqo Tavaux (Nov 2011 , Sept 2012, April 2015 / Int under SCC; Jan 2019 / Nano)

  • Massa (2013)

  • Devnya (Dec 2010; Oct 2017)

  • Povoa (2013; Nov 2018)

  • Roccabianca (June 2014)

  • Aubervillers (09/10/14,Legal entity : Rhodia Operations)

  • Dombasle (10/03/2015) - Int under SCC

  • Bollate (13/04/2015) : substances in authorisation process

  • Linne-Herten (18/04/2016) :No non-compliance identified

  • Rosignano ( Oct 2018)


More questions? contact Valérie Verlinden.


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