Highlights from the General Assembly Meeting
The 2022 General Assembly meeting which took place virtually on May 5th discussed general issues related to the smooth running of the consortium as well as possible threats emanating from ECHA/the Commission by way of potential Restrictions/Authorisation related to the use of several Mn substances within the EU amongst other things.
The meeting saw the following decisions taken
The GA agreed a on methodology to redistribute income from Non-EU REACH data sales. MARA’s assets in the form of study reports are being sold for the purposes of Non-EU regulatory compliance in the hope of sharing knowledge on the toxicity profile of Mn-based substances in view of a worldwide harmonising the classification. The GA agreed that if the entire industry use the same data – then industry will settle for the same classification.
MARA’s Office: The GA discussed the need of an actual office versus a virtual office from a financial standpoint. Considering that work was still effective during the pandemic lockdown, it was clear that a virtual office will reduce cost without affecting the quality of work carried out by the Consortium. To this end, the GA approved for MARA to seek advice from the French authorities on the possibility of a Not-for-profit organisation to be domicile virtually.
Harmonised Categorization of Slags across the EU: The GA approved a way to fund this special project. The project which considers the present regulatory constraints on the use or disposal of slags across the EU to be non-harmonised is aimed at creating a level playing field guided by a harmonised regulatory standpoint for all players within the EU. The project intends to use a robust socio-economic analysis and lobbying of the authorities to achieve its goes.
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