Reconsile and SIEF
Reconsile is a Consortium bringing together the interests of producers, importers and data holders of a large number (250+) of substances which each will have their own SIEF. Reconsile members have identified themselves in each SIEF as SIEF Formation Facilitators (SFF) and are proposing to be the respective Lead Registrants for the substances considered. ReachCentrum has agreed to coordinate SIEF activities on behalf of the SFFs.

ECHA has summarised key principles in the operation of SIEFs. Reconsile subscribes to these principles which include the formation of a consortium to provide practical help with SIEF data-sharing obligations and the preparation of registrations.

Reconsile has identified the need to communicate with more than one thousand Legal Entity Contact Points or distinct email addresses, based on pre-SIEF information downloaded from REACH-IT. In order to communicate efficiently with such a large number of contacts and to comply with REACH transparency requirements, all Legal Entities Contact Points will have received during April 2009 individual invitations to register on a dedicated and secured password-protected website: 

If you believe you should have received this invitation and that for any reason the invitation did not reach you, please contact the ReachCentrum secretariat.

Reconsile SIEF Communications Website
The website will provide the following information to Reconsile members as well as to all Legal Entity Contact Points which have pre-registered any of the silanes and siloxanes pre-registered by at least one Reconsile member:

• Data which either a Reconsile member owns or has a right to reference
• Substance Identification Profiles
• Planned studies
• Classification and labelling information
• Cost of letters of access
• End-uses covered by registration dossier

At the beginning not all information may be available. Registered members will have the option to subscribe to certain pages ensuring that they will be automatically notified by email when the relevant website sections are updated.

SIEF Members Status
On registration the users will be requested to mark their status preference for one of the following categories derived from Cefic guidance:

1. Dormant (the SIEF member does not wish to be actively involved in all SIEF communications)
2. Passive (the SIEF member is interested only in the final part of the joint registration and does not wish to become an active Reconsile member)
3. Active (the SIEF member is interested in becoming an active Reconsile member; ReachCentrum will send to this member an information package allowing him to apply for Reconsile membership)

The Leading and Involved organisations which have the resources to become Active are brought together in Reconsile. The default status is Dormant. If the Legal Entity Contact Point wishes to be informed of SIEF activities by email or to apply for membership of the consortium, he should choose of the two other status categories, preferably before 30 April 2009.

Reconsile SIEF Communications Extranet Costs
Registration is free (the cost of this website will be integrated in the future letters of access); no commitments will be requested from the users who can change their preferred status at any time.

Reconsile SIEF Communications Extranet Registration Process
Acceptance of website registration will be conditional on matching the email addresses and the organisational affiliations as in REACH-IT. This implies that the website users will only have access to the data of the substances they have pre-registered.

Once the registration has been accepted, the website user (Legal Entity Contact Point) will be presented with a list of siloxanes and silane substances he or she has pre-registered. By selecting one of these substances by CAS Number, he will open a page which he can use to indicate whether he has data to share. On the same page, he will be able to enter data required to establish sameness with the substance made by Reconsile members.

Sameness – An Introduction
Working through a technical consultant: Peter Fisk Associates Ltd. Reconsile has prepared Substance Identification Profiles (SIPs) which will be used as reference documents to check sameness. The SIPs consist of a non-confidential section open to all registrants and confidential annexes giving company-specific details – these are only available to ReachCentrum and the consultant. Further details about the analytical information required for sameness checking are summarized here.

As the substance sameness check is the last step in converting the Pre-SIEF into the SIEF, all registrants to the Reconsile Extranet are kindly requested to read and execute the 'Sameness Checking Procedure' by checking the box next to the following statement:

'I confirm that the properties of my substance meet the description in the SIP'

Organisations which have been invited to complete the Sameness Checking Procedure but which fail to do so will no become members of the SIEF.

Sameness Checking Procedure

1. On the Reconsile SIEF Communications Extranet the SIP's for at least the 2010 deadline (Phase 1) substances are available to candidate co-registrants of the relevant substances.
   
2. The candidate co-registrant must check the SIP and compare the specifications of its substances with the SIP. It will conclude whether its specifications are in line with the SIP.
   
3. In case the candidate co-registrant concludes that is own substance specifications are within the SIP, he must indicate in the Reconsile Extranet that its substance meets the specifications as described in the SIP by checking the appropriate tick box.
   
4. Closing time for the SIP confirmation is 30 November 2009.

Communications between SIEF members
The website will provide to the users the ability to communicate with other SIEF members and to receive emails addressed by ReachCentrum or by SIEF Formation Facilitators.

Lead Registrant Agreement
REACH requires that SIEF members formally agree to a Lead Registrant. The website will present to each SIEF member the following options:

• Accepting Reconsile’s proposal
• Abstaining
• Selecting an alternative Lead Registrant among the other SIEF member organisations

The Reconsile Lead Registrant Agreement process ended on 31 August 2009. The Lead Registrant Agreement process may continue on a substance by substance basis until the process is closed a reasonable time prior to the intended Registration of the substance. As long as the Agreement process is on-going, the acting Lead Registrant will either be the organisation proposed by Reconsile, or the organisation having obtained the majority of the votes expressed. SIEF members will be informed of the outcome of the polling process.