Published: 12 June, 2018
The EU REACH Regulation (No 1907/2006) requires the ‘safe use’ of chemicals throughout the supply chain. In order to help actors comply with this requirement, REACH details specific duties and obligations on each member of the supply chain i.e. the manufacturers, importers and downstream users of the substances, with a large emphasis on communication. One communication tool imposed by REACH is the exposure scenario.
An exposure scenario describes how the exposure of humans and the environment to the substance can be controlled to ensure its safe use. An extended safety data sheet, with exposure scenarios attached, has to be supplied if a hazardous substance is registered in a quantity above 10 tonnes per year per registrant. Exposure scenarios are not limited to only one use and are made up of “contributing scenarios” which describe each contributing activity within the identified use. Contributing scenarios include, but are not limited to mixing, transferring into small containers and applying a substance by spraying.
As registered substances make the way down the supply chain, downstream users will start to see an increase in SDS containing exposure scenarios (also known as ‘eSDS’). When an eSDS is received, downstream users will need to establish what obligations are applicable to them and what they have to do to be compliant. The first step in this process is to check whether your use(s) is covered, however you also may have to consider the use of your customers.
If you find your use is not covered there are several options you will need to consider;
1) Contact your supplier to have the ES updated with your use covered
2) Change your process to implement the ES
3) Substitute with another substance or process or stop the activity
4) Find a supplier providing ES that covers your conditions
5) Prepare downstream user chemical safety report (DU CSR) to establish safe conditions for the use not covered in ES and report unsupported use to ECHA
Each of these options comes with its own pros and cons and determining which option is best for you can be daunting. Here at Yordas Group, our Hazard Communication team are well versed in exposure scenario requirements In order to help you identify your obligations. Why not join Tarn Brown for our free webinar ‘Downstream User Exposure Scenario obligations’ on Friday 13th July to find out more. Sign up here.