ECHA

Implementing REACH is one of the most challenging tasks that the European chemicals industry has faced. At Kao Chemicals Europe (KCE), we have a team of five professionals working to fulfil the regulatory obligations as a manufacturer, importer, downstream user and only representative. We describe some of our experiences with REACH here, particularly from a downstream user perspective.

22% registered

As a downstream user, we buy over 1 000 raw materials a year and about 22% of these have been registered so far. We have received extended safety data sheets for about 16% of these registered substances. These extended safety data sheets summarise the key information from the chemical safety assessments carried out as part of the registration process.

We require all of our European and non-European suppliers to complete a so-called "Certificate of Regulatory Compliance". With this document, we gather information about the pre-registration and registration status of substances and products supplied to us.

Sometimes it can be difficult to receive all the answers through this certificate but, if needed, we follow up by contacting the supplier directly. Since the certificate is integrated into our internal chemicals management, all communications are archived so that they are easy to retrieve if we have inspections, internal audits or receive questions from customers.

We ourselves have registered over 100 substances. After our registrations are finalised, we communicate all relevant information to downstream users through the extended safety data sheet.

Missing uses?

As a supplier, we have been surprised to have only received a few requests to cover missing uses in our extended safety data sheets. This might be because of the complexity and length of these documents but also because there is no standardised way to communicate uses and exposure scenarios yet. This can cause misunderstandings and difficulties when trying to interpret the information. We are aware that ECHA and industry are working on this issue, and we think this is a positive step.

In all cases where a missing use was reported to us, we checked the registration and noticed that the use was covered but the exposure scenario for it was not added to the extended safety data sheet that was sent to our customer. In these cases, we have been able to send an updated extended safety data sheet including the exposure scenario without needing to update the registration dossier.

Checking exposure scenarios

When we receive an extended safety data sheet for our raw materials, we check that our uses are described in it. If they are not, we contact the supplier to discuss if the missing uses can be included and whether a new extended safety data sheet can be provided. In most cases, an informal discussion showed that the use was already considered by the registrant, but not communicated.

If the use is not covered, the necessary assessment can be done either by the supplier or the downstream user. In our experience, the supplier has usually agreed to carry out the necessary chemical safety assessment, create the chemical safety report and adapt the extended safety data sheet.

In certain cases where we wanted to keep our use confidential, we decided to carry out the assessment of the use ourselves. Consequently, we also prepared the chemical safety report. For this, communication between the supplier and downstream user is vital because the supplier has much of the information needed for the assessment.

ECHA's dissemination portal can also be a useful source if the information cannot be received from the extended safety data sheets or from the supplier.

Support from sector associations

Sector groups of European associations can offer support and help to share the workload of downstream users. We have been involved in the REACH activities of several associations from the very beginning.

One of the main activities has been providing support for downstream users. They have, for example, promoted the use maps for each industrial sector. As registrants we have used the use maps relevant to our specific sector (such as those developed by, for example, AISE, Cosmetics Europe or IFRA) to make communication easier through the supply chain. Even though the use maps can be too broad for our particular need, we feel that they are very useful when we are trying to harmonise use descriptions. However, this may result in a huge number of exposure scenarios.

Companies and sector associations have also been working together to develop new ways of communicating safe use information. One example of this is the Safe Use of Mixture Information (SUMI). The SUMI aims to make the safe use information for mixtures more understandable for downstream users. We are currently collaborating with a sector association to develop a SUMI for one of our products.

We also recommend downstream users to look for further information on ECHA's website, which contains information on registered substances, questions and answers, and many useful guidance documents. You should also contact your national helpdesks for advice. Our national Spanish helpdesk has been an excellent first point of contact for many of our questions.

REACH compliance as added value

One of our aims at KCE is to take responsibility for the environment and for health and safety throughout the life cycle of our products. We find that it brings added value to our products when the substance's hazards and risks are taken into consideration at the very early stages of product development.

From a downstream user's point of view, we want our suppliers to have the same aim and to fulfil it. For this, REACH is helping a lot.

From the left: Michael Top, Samantha Schiavon, Emili Sapés, Marta Galobardes and Àlvar Sala. Image: Kao Chemicals Europe, S.L.

Further information:

• Information for downstream users
• Who is a downstream user under REACH and CLP? (video)
• Q&As on REACH
• Guidance documents
• Helpdesks
• Terminology – in 23 language

Kao Chemicals Europe, S.L.   Kao Chemicals Europe (KCE) is the European branch of the Kao Corporation Japan. Kao Japan is known on the Asian market as a producer of cosmetics and household products, but also has a large chemical branch. KCE has its origins in surfactant technology and deals with products that are, for example, addressed to personal care, laundry and cleaning, and technical application markets. The implementation of REACH is organised centrally by the KCE Product Safety department. Five of its members are dedicated to work on REACH. http://www.kaochemicals-eu.com/ http://www.kao.com/jp/en/corp/

Text by Samantha Schiavon, Michael Top, Marta Galobardes, Emili Sapés and Àlvar Sala, Kao Chemicals Europe, S.L.

If you liked this article, you may also like: Make sense of safety data sheets and exposure scenarios – a new eGuide, Newsletter 4/2014 From registrant to downstream user – implementing REACH the Yara way, Newsletter 3/2014 What to do when received an extended safety data sheet, Newsletter 4/2013