ECHA

Anyone using chemical substances and products needs to know how to use them safely. But how can we manage the increase in information generated by REACH? We spoke to three sector organisations to learn more about the use maps they have developed for their sectors and the benefits for registrants and downstream users.

 

What is a use map?

The clue is in the name – it’s a map of the most common ways in which chemical products are used in a particular sector. Why is that important? Because companies need to know how their chemicals are going to be used so they can check they are being used safely. And, downstream users need guidance from companies on how they can be used safely. This communication flow up and down the supply chain is made much easier if you have a standardised use map.

The use map package helps sector organisations collect information on how the chemicals in their sector are used and provides this information in a structured and standardised way for registrants. The package contains four templates:

• One to describe the uses; and
• Three to report the information needed to assess exposure to workers (SWEDs), the environment (SpERCs) and consumers (SCEDs) for those uses.

“The use map template gives a simple overview of the most common uses in a sector and the related contributing activities. The three exposure assessment templates are linked to the use map and literally map out the specific conditions of use,” Ms Divina Gómez from the European Adhesive and Sealant Industry (FEICA) says.

 

What problem do the use maps solve?

Formulators deal with mixtures, but the information they receive from their suppliers in the exposure scenarios is substance-related. Integrating the information is a significant challenge.

Mr Björn-Markus Sude from the Imaging and Printing Association (I&P) explains that safe use information for mixtures is an issue for the imaging and printing sector. “Information in extended safety data sheets needs to be explained in an understandable way for the end user, and with the amount of content increasing due to REACH and other legislation, this is not an easy task.”

“The exposure scenarios received by our member companies are often lengthy and difficult to manage because they have different content and different formats. This makes it difficult to analyse and consolidate the safety information to be communicated downstream to their customers. There is also an issue that they do not reflect reality as they often contain irrelevant or unrealistic operational conditions and risk management measures. We see the improved use maps as a solution for these issues,” Ms Gómez explains.

“Mixture formulators and their suppliers need to talk, but these dialogues can often be difficult when formulating construction chemicals, as they often require many substances subject to registration under REACH. This has caused considerable extra costs and effort for our members,” Mr Martin Glöckner on behalf of the European Federation of Construction Chemicals (EFCC) confirms.

The use maps were developed to overcome these difficulties.

 

How do the use maps help?

By gathering information in the sector use maps, formulators can provide the data once – thereby avoiding requests from multiple companies in their supply chain.

According to Mr Sude, many of their members were receiving ad hoc use-related questions from registrants in their supply chains for substances registered. If registrants have a better description of the use, they can provide better exposure scenarios for communication and this will reduce the amount of use-related questions coming from registrants or downstream users. “With the upcoming 2018 deadline involving so many more substances, the use maps will help our members improve how they communicate their use of substances and mixtures much more efficiently. This is more important than ever.”

“The realistic use descriptions within the package will help registrants make their chemical safety assessment more efficiently, too. Data in the use maps will be representative for the entire sector, which should significantly reduce the communication needs of registrants and formulators. With the data in the templates provided in an electronic format (for example, in Chesar files) registrants can extract the information to use in their exposure assessment tools, eliminating the risk of errors caused when manually transferring data,” Ms Gómez explains.

“With standardised uses across an industry sector and many fixed parameters, the risk assessments should become easier and more consistent to do, although the number of uses will increase with the more detailed description. The upload of files, which are planned for the near future, will help automate the exposure assessment and this should also bring efficiency to the communication process,” Mr Martin Glöckner says.

 

New and improved

The use maps now describe the uses in more detail, breaking down the sector-specific uses into steps and activities and simplifies how the uses and the conditions of use are shown. This allows registrants and risk assessors to easily identify which scenarios are relevant for them, and to check for more specific details for their risk assessments in the related templates of exposure inputs.

The standardised templates give companies within the sectors access to harmonised information on how the substances can be used. “For us, this standardisation is the most significant achievement. Companies within the sector and suppliers selling substances or mixtures into it now receive consistent information, in consistent formats. This allows us to communicate relevant use information to our customers in a concise and understandable form. Having information on the safe use of mixtures (SUMI) available is also a positive element that has not been available before,” tells Mr Glöckner.

The three exposure assessment templates refine the data collected on operational conditions and risk management measures according to the activity types (i.e. for workers, environment or consumers). This results in a more realistic assessment outcome as it covers actual downstream uses.

 

What was the most challenging part of developing the use map?

”The use maps, as such, are not required by law and so this was seen as ‘voluntary’ work. We had to convince companies of the long term benefits for them,” Ms Gómez says.

Creating the use maps requires practical knowledge, expertise and a willingness to collaborate.

“We had to find a way to manage substances with different hazard profiles for the same uses, but which needed different risk management measures. To resolve this we created low, medium and high ‘risk management levels’, which meant that different worker exposure assessments would be available for a use. This allowed registrants to react to substances with different hazard profiles,” Mr Glöckner explains.

For the imaging and printing sector, one of the biggest issues has been the wide range of uses for chemicals. “Our manufacturing and formulating process and the end uses differ greatly, making it difficult to meaningfully map the uses of the substance without becoming unclear. We tried to combine uses but this made them confusing. On the other hand, we ran the risk of adding too much detail for some activities and inputs to the exposure scenarios. So getting this balance right was not always easy,” Mr Sude says.

 

Where are the use maps going next?

After their publication, the next step is to encourage registrants to use them in their chemical safety assessments. There will be events to promote and raise awareness about them amongst downstream users and registrants.

“We hope that registrants will start to use the maps. In the medium term, cross-sector consolidation should be discussed. The idea would be for different sectors to check if they have developed similar templates for exposure to workers, the environment and consumers. If they have, the same templates could be used by different sectors. This would reduce the number used and simplify the entire process. Certain use conditions may be comparable across sectors, so this is also something we will explore,” Mr Glöckner says.

“The Adhesives and Sealant Industry will continue to work on developing ESCom phrases - standard phrases that can be used to complete an exposure scenario for communication. We will also be looking at making the exposure inputs available as Chesar files,” tells Ms Gómez. Having use maps available in a Chesar format helps the work of registrants. Chesar is an application that helps companies assess the safety of their chemicals and prepare chemical safety reports and exposure scenarios to be communicated in the supply chain.

“After our use map and worker exposure templates are published, we will look at the environmental exposure inputs and review the safe use of our mixtures. We have to remember that REACH does not stop with registration in 2018. Communication on uses up and down the supply chain is just beginning and will need to continue,” Mr Sude closes.

 

At the time of writing, information from five sector organisations is available in the use map library on ECHA's website. The sector associations are A.I.S.E., Cosmetics Europe, EFCC, FEICA and I&P Europe. If you want to add your use map to the library, you can do so using a dedicated webform on our website.
 

From left: Divina Gómez, Björn-Markus Sude, Martin Glöckner.

 

How to develop a use map for your sector   Start by identifying the typical uses of substances and the main drivers of the exposure scenarios in your sector. Identify experts within your sector and talk to them to find out how the substances are really used. Limit the scope of the uses you cover – describing too many uses can overcomplicate the use maps. Once you have a draft of the use map, test it out. Explain and share the work with your whole membership. Follow ENES and the CSR/ES Roadmap activities, and discuss the use maps with other downstream user associations and with registrants.

 

Further information:

Use maps

Use maps library

Submitting a new use map

Association of the European Adhesive and Sealant Industry

European Federation for Construction Chemicals

I&P Europe - Imaging and Printing Association e.V.

Chesar

Exchange Network for Exposure Scenarios (ENES)

Chemical safety report/Exposure scenario roadmap

 

Interview by Paul Trouth
Top image: ECHA
Images of the interviewees: Divina Gómez: FEICA; Björn-Markus Sude: I&P Europe; Martin Glöckner: Deutsche Bauchemie e.V.

 

If you liked this article, you may also like: Guest contribution: Avoid a headache on 31 May 2018 – make sure your uses are covered, Newsletter 3/2016 Joining forces to improve downstream users' understanding of EU chemicals legislation, Newsletter 2/2016 Supply chain communication – help yourself, use the tools, Newsletter 1/2016