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- No time to lose – active substance suppliers need to get on the list
- Kao Chemicals Europe - implementing REACH as a registrant and downstream user
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Get wise – use Chesar
Dr Dirk Schwartz from Bruno Bock Thiochemicals has experience from both REACH registration deadlines. Ahead of the second deadline in 2013, his small and medium-sized (SME) company decided to manage their registrations in-house. For the chemical safety assessment included in the registrations, his company uses ECHA's Chemical Safety Assessment and Reporting tool, Chesar. "For me, Chesar is a key tool for managing the safety and exposure of our chemicals," he says.
For the first registration deadline in 2010, Bruno Bock registered eight substances with the help of an external consultant. In 2013, 10 more substances were registered. "We decided in 2011 that we would use the IUCLID and Chesar tools and do everything on our own. We really felt confident that an SME could manage its own registrations," Dr Schwartz mentions.
|Dr Dirk Schwartz.|
A clear advantage was that the company has detailed knowledge of the chemicals it produces. "Our substances have a very clear chemistry; we know the uses, the toxicology and we have everything very well documented. We don't have any CMRs (carcinogenic, mutagenic or toxic to reproduction) or PBTs (persistent, bioaccumulative and toxic) in our portfolio – the hazard we have to care for is sensitisation and toxicity in general. We thought that with this knowledge it must be possible to submit a registration."
Increased independence through Chesar
Dr Schwartz was not familiar with Chesar and needed training before he could start using the tool. "I attended a two-day webinar on the use of Chesar. This reassured me that I could start with the tool."
He is now convinced that Chesar is the best tool for chemical safety assessments. "The charming idea of Chesar is that you can do the chemical safety report (CSR) on your own. It is automatically created through a IUCLID plug-in, and integrates IUCLID and Chesar data to generate a complete CSR. So the data is consistent in the dossier. In my opinion, this is a prerequisite for companies producing chemicals."
Other benefits of Chesar for an SME are that it is free-of-charge and easy to install. "On top of the CSR, you can also use Chesar to create the extension to your safety data sheet (eSDS) to communicate the risks to your customers. This is very important, because SMEs don't always have the budget to hire a consultant to do this," Dr Schwartz says.
Chesar also allows companies to manage the safety information independently when there are changes in the dossiers. "I can update the information whenever I need to, without external help. This saves time and money. It is also a plus that Chesar is built by an authority. Using the tool gives me reassurance that we are applying the regulatory standards."
Starting with practical examples
ECHA has published an illustrative example of a CSR on its website to help companies compile their chemical safety report with Chesar. Dr Schwartz recommends this material to all Chesar newcomers.
"Playing around with the case study files is a good way to get the feeling of how the tool works. In addition, the practical examples for exposure scenarios are helpful too. Unfortunately, not all of the examples include the related Chesar files, which would help you to understand and compare the exposure scenarios from different industries," Dr Schwartz says.
Challenges with support
At present, only around 10% of industry use Chesar for their safety assessments. According to Dr Schwartz this is a pity. "Big companies and associations should focus more on Chesar. For example, the registration of speciality chemicals in a small tonnage band, such as additives, is also important for big firms. So, industry associations should provide companies with specific environmental release categories (spERCs) in a Chesar format," Dr Schwartz explains.
Bruno Bock will register most of their substances, 20-30, by the last deadline of 31 May 2018. The preparations are already underway, but important business decisions still need to be taken. "The difference in costs for registering substances below or above 10 tonnes is significant. Of similar importance is the decision to register substances at either below or above one tonne. The decision on the tonnages has to be reflected in our business strategy for the next three to five years. We have to see whether it is in the interest of our customers to have a registration above 10 tonnes or not," Dr Schwartz says. For registrations below 10 tonnes, a chemical safety report and toxicity screening tests are not needed.
For the 2018 deadline, Bruno Bock will most likely need help from consultants. However, it still wants to store all registration data in-house. "We will continue with Chesar, that's for sure. If we outsource some of the registration preparations, the prerequisite will be for the consultant to work with Chesar," Dr Schwartz concludes.
Did you know?
The chemical safety report (CSR) documents the chemical safety assessment performed as part of the REACH registration. It is the key source from which the registrant provides information through exposure scenarios to all downstream users of chemicals. The CSR is also used as a basis for other REACH processes such as substance evaluation, authorisation and restriction.
ECHA's Chemical Safety Assessment and Reporting Tool, Chesar, helps registrants to carry out the exposure and risk related parts of their chemical safety assessments to generate their chemical safety reports. It also allows the exposure scenarios to be exported for communication in the supply chain.
A new version of Chesar – Chesar 3.0 – will be available in 2016, together with IUCLID 6 and a series of CSA-related Guidance updates. The new release will improve the user friendliness of the tool and include the possibility to assess more complex substances.
- Practical examples of chemical safety reports
- Practical examples of exposure scenarios
- Chemical safety report and toxicity screening tests - OECD 422
- REACH 2018
- Terminology – in 23 languages
Bruno Bock Thiochemicals
Bruno Bock Thiochemicals is a privately owned company founded in 1937 in Hamburg. It employs 100 people in Germany and another 70 in its subsidiary in the United States. The company specialises in manufacturing organic sulphur chemicals and is the world's leading producer of Thioglycolic Acid, 3-Mercaptopropionic Acid, Thiolactic Acid, and their derivative esters, Polythiols and salts. The main uses for these chemicals are in cosmetics, plastic additives, leather products, the polymer industry, water treatment and oilfields, and cleansing products.
Interview by Hanna-Kaisa Torkkeli
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