James Orr and the ORO.
Staying up to date with their industry is crucial for any organisation.
The chemical regulatory industry is impacted by a host of factors: the political environment; scientific advancements; new information requirements; increasing end-users awareness; consumer demand; evolving global, national, and regional regulations; etc…
One of our strategies for staying up-to-date with these factors is our involvement with leading industry organisations, including the Only Representative Organisation (ORO).
Helen Penman and James Orr attended the 2018 1st Technical Meeting of the ORO in Milan, Italy, on the 28th of June, and we caught up with them to find out more:
Helen is the Product Stewardship and Regulatory Affairs (PSRA) Manager and one of the longest standing employees of Penman Consulting. Helen is a regulatory project manager with many years’ experience working closely with large consortia in the chemicals industry and REACH regulation. To find out more about Helen and how she is growing as a Product Steward visit: How do you grow a Product Steward?
James is a Regulatory Affairs Specialist in the PSRA team. He manages our Only Representative services and is the first point of contact for our clients, providing them advice and support on regulatory compliance. James is also experienced in completing co-registrations, SIEF management and using technical programs (e.g. REACH-IT and IUCLID).
“For a Non-EU manufacturer to enter the European market, they require an entity or representative based within the EEA (European Economic Area). An Only Representative (OR), based within the EEA, takes on the Legal obligations of importers, under REACH Article 8, on behalf of a Non-EU manufacturer, allowing them access to the European market. These obligations include keeping up-to-date information on importers and respective annual tonnages and information on the latest version of safety data sheets. This prevents the importer from requiring their own registration and they are considered as a “Downstream User” in terms of REACH.”
The ORO is a group of industry experts representing member companies based throughout Europe, with the common goal of knowledge sharing and striving to improve the standard of Only Representatives throughout the industry. Representatives frequently take part in industry meetings, discussing future developments and concerns in the industry.
“We are part of the ORO to play an active part in knowledge sharing and to keep up to date with best practice. The knowledge and experiences shared by other members are invaluable and help us to provide our clients with a quality service. The ORO have a list of quality standards to join the organisation, including competence and understanding of the relevant articles of the REACH legislation and striving to act in accordance with the ORO Best Practice Guide (available at http://www.onlyrepresentative.org). By being a member, Penman Consulting has met these quality standards.”
“Yes, we received feedback from previous industry meetings, helping us to comply with the complex requirements of being an Only Representative. It is very beneficial to have contacts within a forum of professionals who can answer complex queries. It was also good to meet people in person, to put names to faces from email correspondence.”
“Upcoming Enforcements and the impact that Brexit will have on the industry. The consensus was that until the outcome of Brexit is clearer members should prepare contingency plans to continue operating (as British ORs will no longer meet the requirement to be inside the EU after Brexit) but no immediate action is necessary until the UK position is known. In Penman Consulting’s case, all OR work under the UK company will be transferred to the Belgian entity. As an employee of a Belgian company, based within the UK, it was interesting to hear the perspective of our European colleagues.”
“We took turns around the room to share experiences of the 2018 REACH Registration deadline. This gave everyone a chance to enjoy some light-hearted anecdotes and well-deserved praise to ECHA for their continuous support. It was interesting to note the similarity of experiences shared around the table. – Communication was a key discussion point.”
“It was the first trip to Italy for both of us and we would both love to go back. There is some spectacular architecture (particularly the Duomo di Milano) and the gelato was amazing!”
Staying up to date is vital for the survival of organisations in the chemical industry and participation in industry organisations like the ORO makes it possible. More than that, it allows us to contribute to the debate about future uncertainties and help to develop the right solutions to complex issues.
Keep an eye out for more news about the upcoming issues in the industry and the way in which Penman Consulting is helping our clients to face them.