The 2020 GA meeting which normally takes place in May was postponed to November 4th due to the global pandemic. The November 4th meeting which was virtual saw 20 attendees and lasted an hour as most of the GA mandated task/decisions were addressed by way of votes prior to the meeting. Chaired by Interim Chairman Dr Bernd Friede, the meeting though brief was effective with some key decisions taken as follows:
Some highlights:
- Executive Committee: A new Executive team was endorsed with the 2nd Vice-Chairman becoming the Chairman and Secretary General maintained to ensure continuity
- Non-EU letter of Access Fees: Letter of Access fees and administration fees for non-EU REACH-Like regulations per substance, per legal entity for non-MARA members was established
- Members involvement in Non-EU regulations: MARA members wishing to register substances in non-EU REACH-like regulations will only pay administration fees as they own the data generated by MARA
- Technical update: Three dossiers updated this year lead to a new classification for manganese based UVCB’s
- 2020 Workplan and budget were ratified in Q1, 2020 via round robin votes.
Dossier Updates - Mn, MnSO4, MnO2
Under REACH Registrants are obliged to update their dossiers and in many cases, without undue delay. In 2020, the Commission clarified the terminology - without undue delay as follows:
"A deadline of three months applies for administrative updates, such as a change in a registrant’s status or identity. Meanwhile, a deadline of six, nine or 12 months applies for more complex updates, for example when the classification and labelling of a substance without a harmonised classification changes, or there are changes in the chemical safety report or guidance on safe use. However, when there are multiple reasons for updating a registration, only one submission is required and the longest deadline applies..."
To this end, the following dossiers were updated for the following reasons:
Mn (EC Number: 231-105-1) - CSR update triggers Dossier update: Focus: The 2010 life cycle tree and chemical safety report (CSR) did not accurately reflect the current situation. Therefore,interviews and co-registrants questionnaires provided information covering the entire supply chain – mining, smelting and trading. This more uptodate information was used to revise the understanding of the manganese metal processes, uses and exposure patterns. This was used to update the CSR.
MnSO4 (EC Number: 232-089-9) - CSR update triggers dossier update: Focus: on use and exposure. Assessment reveals all uses from the original dossier ( 2010)are still considered as safe but for consumer use of fertiliser products - PC 12: Fertilisers where only 12.5% of the registered substance can be used in fertilisers. Any concentration above this will lead to significant effects hence falling the risk assessment and triggering a use advised against.
MnO2 (EC number: 215-202-6) - LR request to update supply chain changes
Based on the above updates, a new update CSR is available for those co-registrants that are uptodate with the LoA payments. Please request your new CSR from reach@manganese.org. Note that you are encouraged to update your own joint dossier and use the information inherent in the updated CSR's in your SDS's