creating effective mechanisms for communicating chemical risks to smes under reach

1. Creating Effective Mechanisms for Communicating Chemical Risks to SMEs under REACH

2. REACH raises many challenges for industry The Registration of chemicals represents a major burden for manufacturers and importers. Much less discussion has been devoted to the nature of the changes that REACH will bring for users of chemicals One of REACH's primary objectives is to ensure that the use of chemicals does not constitute a risk to man or the environment. REACH Exposure Scenarios potentially represent a major step forward if they are able to effectively communicate useful information to users of chemicals. Relevant, correct, understandable Consistent across suppliers of identical and similar substances Background

3. Considerations for Effective Communication Effective communication is neither straightforward nor easy. Most chemical supply chains are complex A series of, sometimes conflicting, demands have to be addressed and reconciled before chemical suppliers are in a position to routinely provide such advice. Not least amongst these demands is the challenge of how the safe use of chemicals can be described in a manner that is understandable to SMEs whilst serving the primary REACH objective of conveying the measures required to ensure the safe use for man and the environment. Relevant, correct, understandable Consistent across suppliers of identical and similar substances

4. REACH Basics REACH requires the phased registration by manufacturers and importers (M/I) of all substances manufactured or imported at >1 tpa Starting in 2010 and ending in 2018 For substances produced at >10tpa, the Registration requires that a risk assessment (termed a Chemical Safety Assessment, CSA) is provided to demonstrate the adequate control of risks (health and environmental) The control is shown via Exposure Scenarios (ES) that describe safe use throughout the life cycle of the (classified) substance The ES are required to be communicated in an Annex to the SDS (described as the extended safety data sheet, eSDS) and adopted by users >1 tpa for substances of very high concern, SVHCs (CMRS and PBTs)

5. Developing & Communicating ESs

6. Alignment With Other OSH Advice It would appear a sensible start point to ensure that emerging REACH-based OSH advice aligns with existing regulatory recommendations on the safe use of chemicals Similar OSH risk communications challenges have already been addressed within various European structures, E.g. UK COSHH Essentials scheme; the EMKG approach of the BAuA; the activities of the Kooperationsstelle Hamburg. While these accommodate ad hoc enquiries, they have not been designed for incorporation into the systems that support routine communication within chemicals supply chains e.g. safety data sheets. And they do not address environmental concerns CEFIC has further refined these proven concepts to develop 'generic Exposure Scenarios'

7. GESs : One Solution It is inefficient and potentially confusing to create ESs for all possible use profiles of a product, especially for substances in dispersive use Different formats, potentially conflicting risk control advice from different M/I�s, extensive amount of work, safety data �books� Generic Exposure Scenarios (GES) focus on the principal applications of a substance (or groups of similar substances) within an area of industry. Based on a composite of common areas of use Developed by Industry in partnership with DU trade associations Undertaken in accordance with the requirements of REACH And additionally identify and characterise �sector good practice� Ability to be incorporated into and shared within GES libraries, delivering consistency across industry Provide ability for improved access to risk management information in advance of REACH phase-in dates Are written and structured using standard phrases

8. Current GES Titles for Solvents Manufacture incl. use as Intermediate (I) Distribution (I) Formulation & packing of solvent-based mixtures (I) Use in Coatings (I, P & C) Use in Cleaning agents (I, P & C) Lubricants (I, P & C) Functional fluids (I, P & C) Use in Oil field drilling and production operations (I,P) Metal working fluids / rolling oils (I,P) Blowing agents (I) Release agents & binders (I, P) Agrochemical use (P, C) Road and construction operations (P) Other consumer uses (C) De-icing and anti-icing applications (P, C) Polymer processing (I, P) Rubber manufacture and processing (I) Water treatment chemicals (I, P & C) Explosive manufacture and use (P) Mining chemicals (I) Use in laboratories (I, P)

9. prisme2 Cefic is a partner in the Healthy Workplaces Campaign. Cefic is committed to address OHS risk assessment in SME workshops via the EU co-financed Corporate Social Responsibility project for SMEs, "prisme2". A toolbox with comprehensive EHS instruments practical for SMEs is under preparation. The approach is undergoing piloting in 6 countries (UK, GER, GR, Cz, Sk, Spain) CEFIC expects to organize 18 supporting SME workshops by May 2010 (start was in May 2009 in Greece). REACH and Exposure Scenarios have been/will be on the agendas of several prisme2 events

10. Summary CEFIC members are actively working to fulfill their obligations under REACH and to ensure that the resultant work products remain relevant and understandable for SME users CEFIC has been working with the Commission, ECHA and others to share the results : GESs are now Reflected in the REACH Technical Guidance Being addressed by commercial safety data sheet system providers GES libraries are being developed within CEFIC and will be further publicised next year And libraries of supporting REACH-related standard phrases are being coordinated by BDI on behalf of Business Europe