REACH Round Table Q&As:

Questions from 2009:

Annelie Struessmann, PhD

The REACH Round Table is an opportunity for cosmetic chemists, R&D managers and other industry professionals to submit questions and comments about the REACH legislation in Europe for response by expert Annelie Struessmann, PhD, of CONUSBAT (Aachen, Germany). Struessmann has more than 20 years of industry experience in regulatory affairs and product safety, application and product R&D and technical marketing.

Please Note:

This information on REACH is the opinion of participants of this website and is not meant to be used as a substitute for legal counsel. Allured Business Media assumes no liability for customer use of this information - see our Legal Terms for more information.

Q.Is extraction of palm kernel oil using a solvent (hexane) not allowed to be imported into EU countries? Is there any new regulation on this? If there is, why? - Anonymous, October 26, 2009

A.Palm kernel oil using hexane as an extraction solvent is allowed for import into the EU. It is exempt from the obligation to be registered within the provisions of REACH according to REACH Annex V(9). REACH is the European regulatory framework for chemicals which has been effective since 2007.

Q.Does anyone know if bronopol has been registered under REACH regulations? - Paul H, October 26, 2009

A.You are most likely referring to REACH Article 15: Substances in plant protection and biocidal products.

Active substances with use in either plant protection or biocidal products will be regarded as being registered when administered within the regulatory frameworks applying to these substances (see Article 15). As such, bronopol would be considered as being registered when used in these applications; however, it is not considered registered when used in cosmetic products. All quantities used in cosmetics have to be registered within the REACH provisions. In case you are an actor within the supply chain, you should use a supplier that is REACH compliant.

Q.The use of alcohol in cosmetics is obviously regulated in most countries. The use of denatured alcohol or materials that render the alcohol present denatured prevents this from being an issue for most products. What are the global regulations for the import/export and use of products that contain alcohol and no denaturing materials? - Peter Liversidge, October 26, 2009

Your question goes far beyond the scope of the REACH Round Table, which is directed towards the European Regulation for Chemicals, REACH. I can confirm that REACH applies to ethanol when used in personal care products.

Q.Is soap noodle is a chemical substence? - Dr. Alok Awasthi, October 26, 2009

A.I would consider it as a substance of unknown or variable composition, complex reaction product or biological material (UVCB).

Keep in mind that soap is exempt from registration under REACH according to Annex V which lists: vegetable fats, vegetable oils and vegetable waxes; animal fats, animal oils and animal waxes; fatty acids from C6 to C24 and their potassium, sodium, calcium and magnesium salts; and glycerol.

Q.Is extraction of palm kernel oil using a solvent (hexane) not allowed to be imported into EU countries? Is there any new regulation on this? If there is, why? - Anonymous, September 25, 2009

A.Palm kernel oil using hexane as an extraction solvent is allowed for import into the EU when registered (respectively pre-registered) within the provisions of REACH. REACH is the European regulatory framework for chemicals, which has been effective since 2007.

Q.Please help me locate the CAS number of fiberglass. - Anonymous, September 25, 2009

I suggest to search the Web site: http://www.chemindustry.com/chemicals/993208.html

Q.Our company is participating in the SIEFs for Stearate, CAS no 200-313-4. We would like to know whether a Consortium exists for this substance - Vasili Nicoletopoulos, September 25, 2009

EC 200-313-4 is stearic acid. For any question on potential existing consortia, I would contact APAG, the European Oleochemicals and Allied Products Group, which represents the European producers of Fatty Acids, Glycerine, Alcohols, Metallic Soaps and Fatty Nitriles & their Derivatives and Fatty Esters.

Please also check if the following Annex V(9) applies: The following substances obtained from natural sources, if they are not chemically modified, unless they meet the criteria for classification as dangerous according to Directive 67/548/EEC with the exception of those only classified as flammable [R10], as a skin irritant [R38] or as an eye irritant [R36] or unless they are persistent, bioaccumulative and toxic or very persistent and very bioaccumulative in accordance with the criteria set out in Annex XIII or unless they were identified in accordance with Article 59(1) at least two years previously as substances giving rise to an equivalent level of concern as set out in Article 57(f): Vegetable fats, vegetable oils, vegetable waxes; animal fats, animal oils, animal waxes; fatty acids from C6 to C24 and their potassium, sodium, calcium and magnesium salts; glycerol.

Q.You mentioned that if substance has ELINCS number it is considered as being register. Can you please expain it more? Also, can you please reference REACH documents in which it is written? - Anonymous, September 25, 2009

A substance notified in accordance with Directive 67/548/EEC (Dangerous Substances) was entered into the European List of Notified Chemical Substances (ELINCS).

See REACH: Article 24 for Notified substances

1. A notification in accordance with Directive 67/548/EEC shall be regarded as a registration for the purposes of this Title and the Agency shall assign a registration number by 1 December 2008.

2. If the quantity of a notified substance manufactured or imported per manufacturer or importer reaches the next tonnage threshold under Article 12, the additional required information corresponding to that tonnage threshold, as well as to all the lower tonnage thresholds, shall be submitted in accordance with Articles 10 and 12, unless it has already been submitted in accordance with those Articles.

The EC Inventory consists of European Inventory of Existing Commercial chemical Substances (EINECS)-substances commercially available in the EU before September 1981; European List of Notified Chemical Substances (ELINCS)-substances that became commercially available after September 1981; and No-Longer Polymers (NLP).

Q.Can we change the pre-registration deadline, currently it is 2010, but our volumes would not be >1000 MTPA. Can we lower it down. By doing this, the registration deadline will shift to 2013. Do ECHA charge for such a shift? - Anonymous, September 25, 2009

Complete the following steps for no fee. Go to REACH-IT pre-registration. View pre-registration. Enter EC number and search. Select on pre-registration number. Select tonnage deadline. Change to safe.

Q.According to REACH Regulation, glycerol from a natural based is stated in Annex IV and V (exemption list); however, we had been unofficially informed that there is also an exception to this. We had been informed that natural-based glycerol from a transesterification route (using a catalyst in the reaction) is not exempt as they claimed, and that it is a “chemically treated process” even though a supplier can prove that their product does not contain significant amount of dangerous substances (i.e. methanol and other impurities) and are compliant with European pharmacopeia standards. - Anonymous, September 25, 2009

I do not agree to above view, as provision 9 of Annex V considers substance modifications and not the manufacturing process. However, you do not have a modified glycerol.

Annex V (9): The following substances obtained from natural sources, if they are not chemically modified, unless they meet the criteria for classification as dangerous according to Directive 67/548/EEC with the exception of those only classified as flammable [R10], as a skin irritant [R38] or as an eye irritant [R36] or unless they are persistent, bioaccumulative and toxic or very persistent and very bioaccumulative in accordance with the criteria set out in Annex XIII or unless they were identified in accordance with Article 59(1) at least two years previously as substances giving rise to an equivalent level of concern as set out in Article 57(f):

Vegetable fats, vegetable oils, vegetable waxes; animal fats, animal oils, animal waxes; fatty acids from C6 to C24 and their potassium, sodium, calcium and magnesium salts; glycerol.

Q.Polyethylene Glycols have the generalised CAS reference of 25322-68-3. This reference seems to be on all MSDS supplied for this polymer. With this in-mind our company has pre regsitered using this CAS reference. We have now been told by certain polymer suppliers that this is not a true representation of this polymer type. There is no intention to complete registration, but still may be required to justify the pre registration - opinon welcomed. - Anonymous, June 02, 2009

EC# - 500-038-2

CAS# - 25322-68-3

Substance Name - Poly(oxy-1,2-ethanediyl),α-hydro-ω-hydroxy- Ethane-1,2-diol, ethoxylated

Description - 1 - 4.5 moles ethoxylated

The CAS number represents the various PEGs. Under REACH, it is important that polymers are exempt from registration; however, those PEGs with 1-4,5 moles EO do not comply with the definition for polymers according to the 7th amendment of the Council Directive 67/548/EEC, as such not with the REACH definition for polymers. They are so-called ‘no longer polymers’ and have to be registered (preregistered) under REACH.

Therefore, your preregistration covers those PEGs with chain lengths of 1-4,5 moles EO. If you have other PEGs with longer chain lengths, these are exempt from registration, respectively preregistration. However, according to REACH, the monomer (EO) has to be registered (preregistered). Have in mind that for EO, due to the hazardous potentials, the first registration deadline of December 2010 applies.

Q.We have been advised in the past that glycerin is exempt from REACH. The manufacturers have stated that the product is 99.5%. They also state that the product is refined from 100% vegetable based oil. The problem which now troubles me is the manufacturers have now preregistered Glycerol 200-289-5 through an OR. When I check the preregistration lists, there only seems to be one registration intention for glycerol, leaving me to feel that this product is still exempt. Is this right? - Anonymous, June 02, 2009

A.Glycerol is exempt according to Annex V (9). See COMMISSION REGULATION (EC) No 987/2008

Q.In order to import creams made of natural ingredients without preservatives from the United States to EU countries, what measures do we have to take to legally distribute them? - Jacqueline, June 02, 2009

A.The importer of your products needs to fully comply with the provisions of REACH. This means that all substances contained in the ingredients of the products need to be registered with the European Chemicals Agency before the importation. However, this applies only to substances imported in quantities of 1 ton or more. Several issues should be considered, e.g., if you use only ingredients that have been registered by an actor up the supply chain. Also, natural ingredients are exempt from registration but only when they are following the definition of naturals given in the REACH Regulation. You need to identify your responsibilities immediately as REACH went into effect in June 2008.

Q.We are non-EU cosmetic manufacturer. We have appointed someone in the EU to preregister substances that we import in quantitities over 1ton/year, and we have now started to get emails from SIEF. We now realize that our raw material suppliers have already preregistered some of these raw materials. Can we just use the suppliers' (pre)registration information and ignore the SIEF emails? - Jaycee, June 02, 2009

A.As a non-EU manufacturer you have to work with your OR as he /she is the member of the SIEF based on the preregistration made. You also have to communicate through the OR that you do not want to register certain substances, as these will be registered by the supplier. The OR should inform the SIEF facilitator, the person who made the email contact, that no active participation is wanted. He/she may also deactivate the pre-SIEF participation in REACH-IT.

Q.If we export some textile and clothing to the EU. Should our importer in the EU register it due to REACH? Are there any charge for it? - Anonymous, May 06, 2009

Clothing or textiles are articles under REACH, and all provisions under REACH for articles apply. The obligations of your importer include:

- A registration within the provisions of REACH if the articles contain a substance which is intended to be released under normal or reasonably foreseeable conditions of use - Art. 7(1b)

-A notification within the provisions of REACH if the articles contain a SVHC (substance of very high concern) – Art.7(2).

A registration or notification of a substance in an article is not required if the substance has already been registered for that use-Article 7(6).

Additional duties include responding to any agency requirement in case ECHA suspects risks to human health or the environment and complying with any restrictions set out in Annex XVII (REACH Regulation). In the case of SVHCs, the recipient of the article, or on request the consumer that uses the article, needs to get provided with sufficient information to allow safe use, as a minimum the name of the substance.

A registration is subject to charge, a notification, to the best of my knowledge, is free, however, further authorization processes may result.

Q.Please let me know whether registration is required in the following cases: 1. Chemically modifying a already registered monomer and using that modified monomer in making polymer. 2. Making a polymer first from already registered monomers and then chemically modifying the monomers to form a new modified polymer. - Pramod, May 06, 2009

In reference to the first case, the new monomer needs to be registered within the provisions of REACH before marketing the polymer. If it is a non-phase-in substance, no preregistration applies, as such no extended deadlines for registration.

In the second case, the substance used as a building block of the polymer needs to be registered within the provisions of REACH. Again, if it is a non-phase-in substance, no preregistration applies, as such no extended deadlines for registration.

No registration is requested if the substances used for the manufacture of the polymer have already been registered up the supply chain (see REACH Article 6(3)).

Q. First of all I would like to thank you for the wonderful job you do in providing free expert advice on C&T magazine online. I have learned a great deal about REACH from you. I read your article in C&T magazine on Dec. 17, 2009, titled "EU Advises: Avoid Supply Disruption by Submitting Non-EINECS Substances." I went on to read the Commission Communication, but I have trouble understanding the last sentence, "For any specific information item missing, the registrant will provide a justification. The missing information wil be submitted without undue delay." Could you please kindly explain what this means? - Liew Kr-er, May 06, 2009

Thank you for your kind acknowledgement and my apologies for my delayed answer. However, I had to get further information about the interpretation of the below line myself, which was not so easy.

For any specific information item missing, the registrant will provide a justification. The missing information will be submitted without undue delay."

This sentence was explained by the Competent Authority of Germany as meaning:

Both, the inquiry as well the subsequent registration have to be performed without any delay.

To better understand this, have in mind that those non-phase in substances that the communication is referring to gained liability for registration from May 31 to June 1, 2008. As such, it was impossible in practice to inquire or to register by June 1, 2008. With the communication, the commission requests this inquiry from these registrants, and both the inquiry (on items missing) and the subsequent registration have to be performed without any delay.

I hope, it is clearer now.

Q.We import essential oils into the EU. Are they considered preparations or substances, since they came out of a single plant. Also, does the SDS require each component in the oil to be listed or does [essential oil] 100% meet REACH requirements? - Anonymous, May 06, 2009

Please see ECHA Guidance for identification and naming of substances in REACH. Most likely your essential oils are substances of unknown or variable composition, complex reaction products or biological materials, also called UVCB substances. Many essential oils have INCI names, CAS and EINECS numbers. As such, they are phase-in chemicals and can be preregistered within the provisions of REACH.

Please check also if your products are exempt from registration, as they may comply with any of the provisions of Annex IV or V.

The MSDS requirements: REACH Article 31(2) says,

"Any actor in the supply chain who is required, under Articles 14 or 37, to carry out a chemical safety assessment for a substance shall ensure that the information in the safety data sheet is consistent with the information in this assessment. If the safety data sheet is developed for a preparation and the actor in the supply chain has prepared a chemical safety assessment for that preparation, it is sufficient if the information in the safety data sheet is consistent with the chemical safety report for the preparation instead of with the chemical safety report for each substance in the preparation.

In other words, if your classification results from the preparation, the essential oil, then you need to provide the information on the preparation, e.g. CAS, EINECS, chemical name, etc.

Q.The monomer that I am using is already preregistered. If I chemically modify the monomer, then would I oblige to register the said chemically modified monomer under REACH?
- Pramod, May 06, 2009

A.Yes, because it a new substance.
A substance means a chemical element and its compounds in the natural state or obtained by any manufacturing process, including any additive necessary to preserve its stability and any impurity deriving from the process used, but excluding any solvent which may be separated without affecting the stability of the substance or changing its composition.

Q.If a joint submission of documents for a particular substance is done in 2010, would other companies whose registration deadline is 2013 need to submit a separate dossier? Why is this the case, as ECHA already has all the information related to that substance and ideally should not ask companies to submit the data required for preregistration. What are your thoughts?
- Anonymous, May 06, 2009

A.
The dossier content requirements are lower for a later registration deadline (lower tonnages); however, the dossier could be submitted jointly in 2010. The ECHA requests a registration including a dossier from all manufacturers or importers of a substance at any time before entering the EU market. With preregistration, extended registration deadlines are granted to phase-in substances, substances that have been on the market before June 2008. The companies have to assure the similarity of the substance and have to share data. Data sharing is supposed to avoid repeating of tests, especially animal testing, and means also the sharing of the costs of testing.
Generally, ECHA’s registration provisions urge companies to review and assure the safety of chemicals at any time before marketing their products in the European Union.

Q.Why is it that animal fats such as lard cannot be used in the making if soap, yet is available for consumption in supermarkets. Is this definitive or would certain suppliers raw ingredients be acceptable. Thanks
- Anonymous, May 06, 2009

A.
COMMISSION DIRECTIVE 2006/78/EC of Sept. 29 2006 amending Council Directive 76/768/EEC, concerning cosmetic products, for the purposes of adapting Annex II thereto to technical progress is laying down the provisions for use of animal by-products in cosmetic products:
(1) Animal by-products falling within Category 1 material or Category 2 material pursuant to Regulation (EC) No 1774/2002 of the European Parliament and of the Council of 3 October 2002 laying down health rules concerning animal by-products not intended for human consumption are prohibited from entering the production chain for a technical product, such as a cosmetic product. The sourcing restrictions thus imposed on cosmetic products produced within the Community should be extended to cover imported products.
With that Annex II (List of substances which must not form part of the composition of cosmetic products)/419 of the Cosmetics Directive was changed to: Category 1 material and Category 2 material as defined in Articles 4 and 5 respectively of Regulation (EC) No 1774/2002 of the European Parliament and of the Council (*), and ingredients derived therefrom.
Please visit
http://ec.europa.eu/enterprise/cosmetics/cosing/index.cfm?fuseaction=search.details&id=31080 for animal by-products concerned (see also Regulation (EC) No 1774/2002 for Category 1 or Category 2 materials). This list does not include fats which are also used in human consumption, but these fats only include marrow, brain or spinal lipids.

Q.Our current tonnage volume of one substance is 100 MT/A, which has a registration deadline of 2013. However, if it increases to more than 1000 MT/A in 2011, what should we do?
- Anonymous, May 06, 2009

A.You have to file and submit the dossier fulfilling the requirements for the higher tonnage before reaching the threshold. I recommend approaching the full dossier within your SIEF immediately.

Q.we are asked by our OR to commit ourselves to register the substances we have pre registered through them and which should be registered in 2018. Can't we just participate to the SIEF and decide later about the registration? Thank you in advance for your input.
- Anonymous, March 18, 2009

A.By law, it is the OR that participates in the SIEFs. It is wise to decide on the registration now, as otherwise there is no reason or goal for the OR to participate. If you decide on registration later, then the OR should join the SIEF later. The conditions for data exchange may then be slightly different and less favourable.

Q.We are non-EU manufacturer exporting to EU and pre-registered through an OR. We have two manufacturing sites/companies out of the EU. What are the pro/cons in registering separately for these separate sites as oppose to single site via the OR?
- Choong WT, March 18, 2009

A.All provisions have to be fulfilled. A “non-community manufacturer” has to be a natural or legal person that is manufacturing a substance, formulating a preparation or producing an article that is imported into the community. Also, the responsibility of the “non-community manufacturer” to provide his only representative with up-to-date information on the list of EU importers, which should be covered by the registration and the quantities imported into the EU, has to be clearly fulfilled. If that is all assured, then one registration of the same substance is more cost efficient than two registrations.

Q.With the global economy including the chemical industry in such bad financial condition, what would happen if the industry cannot afford REACH? This includes the cost of SIEFs, testing and registration?
- David C. Steinberg, March 18, 2009

A.I cannot believe that it is "the industry" that will not be able to afford the money; however, there will be some, mainly smaller, companies where it will be the case. So, REACH will cause a selection for companies that will be able to do business in Europe. And there will be new, different companies doing business in Europe. I just observed that some internationally operating organizations are taking the facilitator roles of the SIEFs, obviously considered as good business by those companies.

Q.Thanks for your reply to my question on the authorization proces of a substance containing 0.15% of impurity. I just wanted to confirm that our product is a substance and not preparation.
- Deepak Joishar, February 04, 2009

A."Article 3(2): preparation: means a mixture or solution composed of two or more substances"
I took the definition of a preparation under REACH, Article 3(2). As such, you have a mixture of your substances plus the substance of very high concern.

Q.If a substance undergoes animal testing as part of registration for REACH, and is then registered for use in cosmetics and toiletries, does this mean it cannot be used in cosmetics and toiletries because under the Cosmetics Directive, substances cannot be tested on animals for use in cosmetics after March 09?
- Anonymous, February 03, 2009

A.This question is heavily discussed amongst the ingredient suppliers for cosmetics in Europe. We all know the wording of the Article 4 and the actual situation, i.e. that there will not be sufficient validated alternative protocols for certain toxicological tests as required under REACH. The contents of the discussions are diverse and most often controversial. Therefore, I cannot give a solution, as there is no common one. I will try to get a statement from a Cosmetic’s Association.

Q.In Article 2(6), where it says "The provisions of Title IV shall not apply to the following preparations in the finished state, intended for the final user: (a)...(b) cosmetic products as defined in Directive 76/768/EEC;...." could you please kindly explain what this means and how it is applied in the cosmetics industry?
- Liew Kr-er, February 03, 2009

A.Tile IV regulates > Requirements for safety data sheets. Consequently Article 2(6) expresses that no SDS needs to be provided for cosmetics and personal care products. In other words, the manufacturers of these personal care products do not need to provide the consumers with a SDS according to the REACH requirements described in Title IV.

Q.Is REACH applicable for stearic acid, specifically rubbergrade, cosmetic grade or triple pressed?
- Gaurav Misra, February 03, 2009

A.Yes, stearic acid is a substance according to the REACH terminology and requires registration within the provisions of REACH. The grade is of minor importance for this basic decision; however, for further specifics, see the chapter on mono constituents in "Guidance for identification and naming of substances under REACH."

Q.I want to export hair spray into the EU market from the United States. The main ingredient, which is about 50%, is not pre-registered by an ingredient supplier. What should I do to be compliant with REACH? Also if I sell the final product less than 10,000 units/year, no ingredients exceed 1 ton threshhold. If I limit my sales to 10,000 units/year, no registration is required, correct?
- Anonymous, February 03, 2009

A.You have to look to the importer. If your importer imports the same substances in other consumer goods, he may exceed the 1 ton/year threshold. So the whole picture is required for making a decision. Options are to change the supplier to one who pre-registered and will register or to check if a late pre-registration may apply. If the importer imports less than 1 ton/year per substance, a registration is not required.

Q.Is palm oil exempted from the REACH regulation?
- Badrihisham, January 22, 2009

A.Yes, according to Annex V(9), vegetable oils are exempt from registration if they are not chemically modified.

Q.We sell a susbtance in EU that contains 0.15% of impurity (generated during the process), not added with intention. This impurity is a SVHC (as per candidate list). Do we need to go through authorization process?
- Deepak Joishar, January 06, 2009

A.Article 56 (REACH) gives a concentration limit of 0.1 % (w/w for non gaseous preparations) as the threshold for authorization requirements; however, it does not exempt any substance in a preparation due to the nature of its origin from any obligation. Therefore, suppliers of preparations not classified as dangerous according to Directive 1999/45/EC have to provide the recipients, upon their requests, with a safety data sheet immediately if the preparations contain a substance on the Candidate List in a concentration of 0.1% or more and 0.2% by volume for gaseous preparations.
Authorization and applications for authorizations apply when the substance will have been included in Annex XIV.

Q.I am a Canadian manufacturer of Nail Gels. I have a very important need to know how to find a first imorter into the EU.We would prefer to deal with a company in the Netherlands. The EU lab is almost finished with the evaluation and we are not able to find a rep. We are also having difficulty knowing who to submit all the information to.
- Stefania Anderson, January 06, 2009

A.From what I understand, you are referring to the EU Cosmetics Directive. If you need a regulatory contact to provide compliance with the Cosmetics Directive, then you can contact me at annelie.struessmann@conusbat.com. However, if you are looking for a sales contact, I cannot be of help.

Q.Our company is a middleman in that we attain fragrance oils on behalf of our customer, then forward them on to the EU for microencapsulation. Once encapsulated, it is returned to us for inclusion into ink for print advertising. Being the middleman, what is our repsonisibility relative to REACH?
- Anonymous, January 06, 2009

A.Basically the importer in the EU of the fragrance oils is responsible for the registration of the substances. If I were the importer, I would approach it by researching if the substances have been registered by an actor up the supply chain. Also, I would check if the I ton/ year threshold will be exceeded. Have in mind that fragrances are preparations of aroma chemicals and other additives. It is these substances that require a registration.

Q.We are a vegetable fats manufacturer. Our products are made from palm oil, palm kernel oil, coconut oil and exotic fats from the seeds of trees. The manufacturing process includes oil extraction, refining, fractionation, hydrogenation and interesterifacation. All our products are for human consumption. Do we need to register our products with REACH?
- TH Goh, January 06, 2009

A.If your products are used in food they are exempt from REACH.
If they are also used in e.g. cosmetics or toiletries, you should check if they qualify for an exemption according to Annex V(9):
The following substances obtained from natural sources, if they are not chemically modified, unless they meet the criteria for classification as dangerous according to Directive 67/548/EEC with the exception of those only classified as flammable [R10], as a skin irritant [R38] or as an eye irritant [R36] or unless they are persistent, bioaccumulative and toxic or very persistent and very bioaccumulative in accordance with the criteria set out in Annex XIII or unless they were identified in accordance with Article 59(1) at least two years previously as substances giving rise to an equivalent level of concern as set out in Article 57(f): Vegetable fats, vegetable oils, vegetable waxes; animal fats, animal oils, animal waxes; fatty acids from C6 to C24 and their potassium, sodium, calcium and magnesium salts; glycerol.
Otherwise, you would need to register the quantities used for this application.

C&T Magazine

REACH Round Table Q&As:

Questions from 2009:

Please Note: