HPV/REACh Analysis

Summary: Assist client staff and members in determining the options for leveraging the REACh 2010 submissions to both minimize duplicative burden on client members (e.g., such as in the HPV program) and industry more broadly to facilitate the prompt delivery of the REACh data and information to EPA.

There are key differences in content, format, and purpose in the REACh dossiers as compared to traditional HPV submittals. REACh dossiers are, in essence, a license to produce. Data ownership or access rights must be demonstrated. These differences impact individual company abilities to use data collected in REACh efforts for other purposes. Understanding these differences can help define potential options for meeting the client?s objectives.

Cardno ENTRIX reviewed, analyzed, and provided a ?high level? analysis of the data elements to be included in an HPV REACh dossier contrasted to traditional HPV submittals.

Additionally, Cardno ENTRIX project staff also provided an analysis of the data sharing and compensation rules and issues as defined in the REACh regulations, ECHA and industry guidance documents, and standard Consortia/SIEF agreements.

Additionally, they provided an analysis of what is known or anticipated regarding public access to REACh dossier hazard information, timing, and available content.

For more information, contact Tom Grumbles at 713-662-1991.