SDS

1. SDS WORKSHOP on EXPOSURE SCENARIOS“Communication in the Supply Chain”Helle Simon ElbroDanish Paint Association in collaboration with DHI

2. Agenda • Danish REACH project • Exposure Scenarios and our assumptions • An example of “Description of Use” • Further work

3. GOAL for Danish REACH projectProtecting/improving business Raw material suppliers Pro-active Sourcing raw materials Producing Products DU company Selling products Customers

4. Tools Raw material suppliers Building Awareness DU company Customers

5. Tools Raw material suppliers Analysis of Product/raw material Assortment (REACH Temperature Measurement) DU company Customers

6. Tools Raw material suppliers Extended Raw Material Description DU company Customers

7. Tools Raw material suppliers Description of Use DU company Customers

8. Agenda • Danish REACH project • Exposure Scenarios and our assumptions • An example of “Description of Use” • Further work

9. USE Substance Raw material Product SDS SDS SDS Registration dossier Extract EXPOSURE SCENARIO Conditions of safe use 1) manufacture 2) use in entire life-cycle. RMM’s 1) Human exposure 2) Environment incl. waste-handling ES CSR EU Agency REACH Exposure Scenarios Manufacturer Paint & Adh. Customer

10. Extract SDS CSR revised SDS SDS Identified use Revision of ES(by M/I) Manufacturer Paint & Adh.

11. NOTIFICATION SDS X X Identified use EU Agency CSR DU SDS Extract Development of ES by DU Manufacturer Break down or Confidential use Paint & Adh.

12. Increasing Complexity Pro-active communication Sector - or National level Better protection of Confidential Information Where will the ES be made? More value for whole industry M/I DU Assumption 1:In general: ES’s should be made as high up in the supply chain as possible, but DU’s are to participate pro-actively - either on sector or national level. (In a few cases DU makes ES’s themselves)

13. Time Years Validation at (industrial) customer Approval at Authorities External documentation Field evaluation Lab-testing Few days Why is it so important to be pro-active? New additive in functional product (wood-stain) Change of solvent based on Certificate of Analysis

14. Substance SDS + = Inherent properties of chemical Final Exposure Scenarios What forms will the ES take? Paint & Adh. Manufacturer Description of Use/ Template Exposure Scenario Assumption 2: DU’s makes description of use/Template Exposure Scenario from which the M/I’s make the final ES to be included in the SDS

15. Customer use Manufacture (own use) Which part of the life-cycle to start from? Paint & Adh. Customer or Assumption 3: In our work, we have started by describing our customers use: - Other actors up the supply chain have similar unit operations - Customers use is less controlled (limited industrial use) - Focus on use of formulatedproduct.

16. Categories of chemicals Which should we have in mind - up front? Raw materials Increasing classification Butanone oxime (alkyd paints) Cobolt siccative (alkyd paints) Additives (water-based paints) Water Assumption 4: Uses of all classified substances above a given conc. will need to be identified. - Substances with low classification/conc. may only need confirmation of RMM. - Other substances with higher classification/conc may need “more” precise description of use.

17. WHO WHERE indoor outdoor HOW AMOUNT DURATION RISK MANAGEMENT MEASURES FREQUENCY STP WASTE HANDLING Determinants of exposure

18. Description of use -also includes RMM’s and Waste handling! Paint & Adh. Manufacturer + = Inherent properties of chemical Description of Use/ Template Exposure Scenario Final Exposure Scenarios x Final RMM’s and Waste-handling Current (best) practice: RMM’s and Waste-handling or confirmed

19. Danish REACH project Exposure Scenarios and our assumptions An example of “Description of Use” Further work Agenda

20. Scheme for Description of use WHO WHERE HOW AMOUNT FREQUENCY DURATION RISK MANAGEMENT MEASURES WASTE HANDLING

21. Scheme for Description of use WHO WHERE HOW AMOUNT FREQUENCY DURATION RISK MANAGEMENT MEASURES WASTE HANDLING

22. Scheme for Description of use WHO WHERE HOW AMOUNT FREQUENCY DURATION RISK MANAGMENT MEASURES WASTE HANDLING

23. Scheme for Description of use WHO WHERE HOW AMOUNT FREQUENCY DURATION RISK MANAGEMENT MEASURES WASTE HANDLING

24. Scheme for Description of use WHO WHERE HOW AMOUNT FREQUENCY DURATION RISK MANAGEMENT MEASURES WASTE HANDLING

25. Scheme for Description of use WHO WHERE HOW AMOUNT FREQUENCY DURATION RISK MANAGEMENT MEASURES WASTE HANDLING

26. Scheme for Description of use WHO WHERE HOW AMOUNT FREQUENCY DURATION RISK MANAGEMENT MEASURES WASTE HANDLING

27. Scheme for Description of use WHO WHERE HOW AMOUNT FREQUENCY DURATION RISK MANAGEMENT MEASURES WASTE HANDLING

28. . . . . . . . . . . . . Raw material used in decorative product for brush application by normal consumers. Raw material used in wood protection product for professional spray application at out-door conditions. Filling out “Description of use” DU  Immediate raw material supplier . . .

29. Danish REACH project Exposure Scenarios and our assumptions An example of “Description of Use” Further work Agenda

30. Possible future work 1/2 • Make final Exposure Scenarios • Paint • Adhesive • Collaborate with supplier on raw material to develop right form of Template/Final ES • Collaborate with ‘Arona network’: “ES is still to be defined in practice” • Test concept with Technical Service in DU and with customers

31. Target groups Exposure routes Inhalation Skin contact Consumer Oral Prof. & Industrial Air Soil Water Environment Potential future work 2/2 Amount of material transferred to different exposure routes Human All usages Environment

32. THE END

33. Hse consult: 100% project leader Ad Hoc Consultancy work Danish Paint Association Responsible for Project 60% 30% 60% Dyrup Dana Lim Companies Hempel Pilot work (financed by industry) Project Organisation Project work (100% financed by Danish EPA)  

34. Pilot companies Members of associations Producing members • Examples of product types:Decorative, Marine and Anticorrosive PaintsAdhesives; Sealants; Inks and Wood-protection • Market segments: Consumer, Professional, Industry • Large variation in size of companies:Local niche companies  Nordic based  European  International • Most pilot companies have production in Dk • Most pilot companies are Danish owned Pilot companies

35. Manufacturer Substance DU Company DU Company DU Company DU Company DU Company DU Company External complexity – seen from Manufacturer Nail Varnish remover Distributor Soap & Detergents Professional Application of paint Distributor

36. Re-brander DU Company Manufacturer Manufacturer Manufacturer 20 raw materials pr. product EU External complexity – seen from DU Product Raw material Customer Paint & Adh. Distributor BLACK BOX

37. Production Production Distributor Production Distributor EU Distributor Coping with external complexity! Production Company Sales office for “mother” company Paint & Adh. Distributor (EU based goods) Distributor (import from outside EU)

38. Sales responsible Purchase responsible Technical Service Commercial Technical Customer Technical Dept. R/D HSE HSE Functional communication Supplier Paint & Adh.