- Another successful Stakeholders' Day
- Sixth Stakeholders' Day: Start preparing registrations for 2013 now!
- Still a long way to go for downstream users
- ECHA reports to the Commission on the operation of the RE ACH and CLP Regulations and on non-animal testing
- QSAR Toolbox - increasing confidence in computational assessment
- ECHA Unit for Guidance and Forum Secretariat: Supporting the Forum activities
- Risk Management Interview - Part 2: Authorisation and restriction start to work
- Mr Dan Jørgensen, Vice-Chair of the Environment Committee: Happy with progress but some reason for criticism
- Dr Marion Healy: Non-animal testing methods and the assessment of nanomaterials are examples of special areas of interest
- Mr Benedikt Vogt, Enforcer in Freiburg, Germany: Overall situation is positive
- REACH at Helsinki Chemicals Forum
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Article related to: communicating_about_safety
Still a long way to go for downstream users
Ms Sylvie Lemoine, Director for Technical and Regulatory Affairs at the International Association for Soaps, Detergents and Maintenance Products (A.I.S.E.), was one of the speakers at ECHA's Stakeholders' Day. In this interview, she explains what kind of challenges the downstream users are currently facing.
Ms Sylvie Lemoine says that exposure scenarios cause a lot of challenges for the members of A.I.S.E.
Ms. Lemoine, what are the main issues for your members at the moment?
The first issue, particularly for smaller downstream user companies, is to understand what their new obligations are, what they need to do and when. Managing the deadlines is very difficult for them. The deadlines our members need to meet are usually related to the registration of a substance or to the receipt of updated safety data sheets for these substances. However, the deadlines are not the same for all substances and all suppliers.
Our companies do not know how many safety data sheets they will receive, because they do not know how many of the substances that they use have been registered in 2010. In A.I.S.E., we start also seeing issues related to changes of classification and labelling of substances due to the CLP regulation. These changes have an impact on the mixture classification and can affect our members' business. Most challenges our members face in relation to REACH are about exposure scenarios – what to do with them; how to understand the content; how to "digest" and rework the information; and what if the company discovers problems in the exposure scenarios? In addition, risk management measures recommended by suppliers may not be feasible or they can be too expensive – or possibly a use has not been covered. If a use is advised against, the downstream user has to carry out a chemical safety assessment. On the bright side, there is currently no panic concerning "uses not covered". This does not seem to be an issue to our members at the moment. But we are only at the beginning of the process, so the situation may change.
How do companies tackle the challenges? How do you assist them?
We try to assist them and work with other associations like CEFIC or through a downstream user platform called DUCC. We try to develop practical guidance for exposure scenarios that are based on real cases in the industry and guide our members through the different fields of the exposure scenario and tell them which fields are the most important to check first.
It gets even more complex when we are talking about Safety Data Sheets for mixtures. Once downstream users have received exposure scenarios and managed to assess whether their uses are covered and whether these are within the conditions of use, then they have to extract relevant information and forward it in their own safety data sheets down the supply chain. To do that, a clear methodology is not yet available, only different options and views. To our members the work is particularly complex because they produce mixtures or even mixtures of mixtures.
It is clear that we need to have more examples and test them, but that can only be done when downstream users have received enough exposure scenarios for substances we use in our products. We would like to work together with ECHA to understand options and expectations.
How are the exposure scenarios downstream users have already received?
The attached exposure scenarios are very different in content, in format, in level of detail provided and therefore difficult to compare. Some of them are just extracts of the Chemical Safety Report, others are much more structured. The downstream user platform DUCC will have a workshop at the end of May to discuss best practice on the basis of current exposure scenarios.
What was your main message to the audience here?
There is still a long way to go for downstream users, because a lot of unknown things remain. There is a need to build up practical experience, because the whole concept of exposure scenario is new, firstly to substances, not to mention mixtures. We all know it is a learning-by-doing exercise. Industry and authorities need to work together in a pragmatic way. There are some emerging solutions, and that is good.
What were your expectations for your visit to the Stakeholders' Day?
I always find it useful to come here and get the latest information on the most relevant aspects of REACH. The event is also a good opportunity to talk to ECHA staff. This is very valuable for my work. With time, the presentations have become quite practical, with tips, rather than being theoretical on the obligations and duties only. The new approach is more informative and useful.
What kind of assistance do you expect from ECHA in future?
Just in general: Continue to provide support on downstream obligations, because the REACH text is a little vague on the exact obligations of ECHA. It would also be useful if we could work with ECHA on Safety Data Sheets for mixtures.
And maybe some form of IT support for downstream user communications. The upstream communications are not always structured or harmonised, and you get only partial answers from manufacturers/importers if anything. It is quite chaotic, sometimes emails, sometimes letters. As regards downstream supply chain communications, it would be useful to have another way to communicate the registration status of a substance, instead of a partial Safety Data Sheet. This is not very helpful, and another way to communicate the registration status of a substance would be useful.
There is also a tendency to use the SDS more and more as a REACH-compliance and communication document, for multiple audiences, which deviates from its original purpose. This is also not always helpful.
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