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Article related to: Communicating about safety
Downstream user experience: REACH is fundamental
ECHA Newsletter spoke with Richard Schreurs and Jos Bongers from SPGPrints to hear how REACH and CLP have affected their work and how the data generated is used in their company. REACH is something that everyone in the company now knows as an integral part of their daily work.
SPGPrints acts mainly as a downstream user under REACH. This means that the company has not needed to register any substances themselves, but their uses have been covered by the registrations of their suppliers. According to Dr Schreurs and Mr Bongers, quite many of the substances that SPGPrints uses in their products and processes are due to be registered for the 2018 REACH registration deadline. Although this does not have a direct impact on the workload of the company, the registration intentions of their suppliers can make a big difference to their business.
Know what substances will be available on the market
Whether to register a substance or remove it from the market is always a business decision that the supplier makes. This is something that every downstream user needs to consider. "Some chemicals are not available anymore or their composition has changed. For example, a product that we have used in our plating process is no longer available. It has had a big impact on our work, because it took more than two years for us to find a good alternative," says Mr Bongers, Safety, health and environment manager at SPGPrints.
Therefore, the first piece of advice that Dr Schreurs and Mr Bongers would like to give to other downstream users is to be in a regular dialogue with their suppliers. "We have a system in place where we ask our suppliers if they can supply the substance during the next one, two or five years. If the substance in question is very critical to our business, we do this every year. However, the answer we get is of course only an indication, not a guarantee," Mr Bongers highlights.
Whether to substitute or apply for authorisation
One of the biggest effects of REACH for SPGPrints has been the need to take a critical look at the substances that are used in their products and processes. As an example, they mention the use of chromium VI. "For some of our processes, we need to continue using chromium VI and that is why we are a member of the consortium that is preparing the authorisation dossiers," Dr Schreurs, REACH Specialist at SPGPrints says.
SPGPrints will not be applying for authorisation themselves, but their uses will be covered by their supplier's application. Nonetheless, since the substance is very important for their processes, they decided to be part of the authorisation consortium from the beginning.
SPGPrints is applying for authorisation for some uses of chromium VI while for others, they plan to substitute. "We have done a lot of research on alternatives. The decision on whether to apply for authorisation or to substitute is based on risk assessment and business policy. We have some pilots ongoing to find suitable and safer alternatives and we think that we are on a good track," Mr Bongers explains.
Both preparing the authorisation application and finding a suitable alternative takes a lot time and requires expertise. "For example, carrying out the socio-economic analysis is very difficult. Therefore, it is important to start early and ask for help from those who have the required expertise. This can be, for example, a consultant or your sector-association," Dr Schreurs says.
Improving supply chain communication
To comply with REACH obligations, it is important that communication in the supply chain flows smoothly. According to Mr Bongers, the attitude of both the supplier and customer is key. It is about the real willingness to communicate openly, not just about stricter rules or additional paper work. It needs to be part of the company strategy and management philosophy.
"We started communicating with our suppliers already years ago by sending them letters where we asked if they are planning to register the substances that we use. At the same time, we provided them with our uses and use descriptors," Dr Schreurs explains. SPGPrints' experience of working in this way has been very positive.
"Sometimes we still notice insufficient quality of information in the safety data sheets (SDSs). In those cases, we need to contact the supplier and ask for further explanations. This is particularly important for the product classification of our own formulated mixtures," Mr Bongers says. Dr Schreurs adds that another challenge that the company regularly faces is the different format of the exposure scenarios received from different suppliers. This makes checking the content more time consuming.
Although the quality of safety data sheets is mixed, Dr Schreurs and Mr Bongers see that it has clearly improved since REACH came into force. This helps SPGPrints also in communicating accurate information to their customers.
Information from safety data sheets used for several purposes
"We receive the majority of data through the safety data sheets. We have an SDS authoring system in place to make sure that all of the information we receive gets dealt with systematically and can be easily put into the safety data sheets that we in turn send to our customers," Dr Schreurs explains. In practice, this means that all information from the safety data sheets (registration numbers, toxicity values, derived no-effect levels (DNELs) and predicted no-effect concentrations (PNECs)) are inserted into this internal system.
Systematically recording the information received as part of the SDSs also helps when fulfilling obligations and applying for permits under other legislation. "There are several different pieces of legislation that we need to comply with. There is the Chemicals Agents Directive (CAD), Carcinogens or Mutagens at Work Directive (CMD), Industrial Emissions Directive (IED), the Seveso Directive and the Water Framework Directive," Dr Schreurs points out.
Chemical management system is a must
Dr Schreurs and Mr Bongers remind that all chemical companies should set up a management system to make sure their substances are dealt with in a systematic way and that all requirements under REACH are fulfilled. "We have created our own internal directive which is rolled out to all EU sites and it explains how they should comply with REACH," Dr Schreurs says. The directive consists of six parts:
- A chemical substance database in which all the incoming substances are included;
- A mandatory procedure to check that newly purchased chemicals are not SVHCs, potential SVHCs or CMRs;
- Template letters that can be used when communicating with suppliers and customers on REACH;
- A part on safety data sheets and CLP, explaining how the sites should deal with incoming safety data sheets and check exposure scenarios as well as how the CLP symbols should be used;
- A part on recognising SVHCs, considering applications for authorisation and substitution;
- Instructions for an internal audit that is carried out on a yearly basis.
Customers demanding REACH-compliant products
Customer demand for safer products has also put more pressure on downstream users. For SPGPrints, this is particularly the case with their inks. "We are often contacted by our customers who ask if our products are compliant with REACH and if any of the substances used in our products are on the Candidate List. This emphasises that we need to provide products that do not contain substances of very high concern," Dr Schreurs explains.
To make sure that the company can answer their customers' demands, all new raw materials are checked to make sure that they are not carcinogenic, mutagenic or toxic to reproduction (CMR), substances of very high concern (SVHCs), (or with the potential to become one) before a purchasing decision is made. "Everyone in the company knows the procedure. Before buying anything, they first have to look into the properties of the chemical product. For example, if a substance turns out to be a CMR, they have to look for an alternative."
It is clear that REACH and CLP have resulted in both improvements and more work – Mr Bongers mentions for example increased administration and documentation, as well as costs. However, at the same time, these regulations have become a fundamental part of the business. "Previously, about three to four years ago, REACH didn't live within our company as it does now. It is now accepted and everyone knows the concept of REACH," Dr Schreurs concludes.
Dr Schreurs and Mr Bongers attended the Workshop on the use of REACH/CLP information at industrial sites that took place at ECHA in mid-April. See Dr Schreurs' presentation "How a downstream user deals with REACH (and related chemical legislations)" from the event page.
- Downstream users and communication in the supply chain
- Who is a downstream user under REACH and CLP? (video)
- REACH Authorisation
- Terminology – in 23 languages
Stork Prints was established in 1947, in Boxmeer in the Netherlands. In 2013, it changed its name to SPGPrints.
SPGPrints is a global leader in the textile and graphics printing market, offering rotary screen printing and digital printing solutions for printers and converters in the graphics and textile printing industries. The company also offers a variety of precision metal parts in the medical instruments, automotive, electronics, food, home appliances and process industries.
Interview by Päivi Jokiniemi
Top image: ECHA. From the left: Jos Bongers and Richard Schreurs.
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