What are the obligations?

Transcription

1 Exposure Scenarios and mixtures: What are the obligations? Brenntag Cleaning Seminar 30 March 2017 Dr. Hans Razenberg NVZ

2 Keys to NVZ Founded in Represents ±60 companies and % of the market value Located in Zeist. Portfolio: detergents, maintenance products, disinfectants for both consumer and professional market and also.. Professional cleaning equipment 3 under I roof: NVZ, NCV and NAV. International associations: A.I.S.E. and Eunited Cleaning

3 Rebranding From product driven 3

4 To value driven 4

5 VISION NVZ and her membership, in collaboration with stakeholders, want to create clean, hygienic and sustainable environments for all Dutch residents.

6 The NVZ Team

7 European Detergent Industry

8 Introduction REACH Content REACH Supply Chain Communication Obligations for downstream users REACH in practice: Detergents Sector

9 Introduction REACH Main goal Ensuring a high level of protection of human health & the environment Method Manufacturers and importers of raw materials responsible: no safe use, no market! Collecting and generating data on substances Undertake Chemical Safety Assessment (CSA) for all identified uses in the supply chain Also for use in mixtures Communication of CSA results via Exposure Scenarios (ES)

10 End-user Chemical Safety Assessment REACH Supply Chain Communication SDS SDS Identified Uses Supply Chain Communication: Pre-REACH vs REACH ES SDS Manufacturer Formulator Use information SDS Safe Use Info Use information

11 Upstream communication Downstream users have the right to make their use of a substance an identified use Informing supplier of substance uses Use Descriptor System (PROCs, SU, LCS etc.) Distributors have obligation to pass this on to next actor Deadline: May 31 st 2017 for 2018 registration deadline, or within one month of first supply of substance (new customer) Registrant has obligation to address all identified uses

12 Downstream user obligations Three main obligations after receiving SDS with Exposure Scenarios: 1. Use Check 2. Identify and apply appropriate risk control measures 3. Recommend risk control measures for mixture uses (formulators)

13 Downstream user obligations 1. Use Check Are all my uses of the substance covered in one or more ESs? Formulators: Are the foreseen uses of my mixtures covered? When the substance contributes to CLP classification of mixture If not: action required Inform supplier; or Change supplier/substance; or Perform own DU CSA (if required) Notify ECHA within 6 months of receiving SDS with ESs

14 Downstream user obligations 2. Identify and apply appropriate risk control measures Follow the conditions and risk management measures from The relevant exposure scenario(s); or The results from my own DU CSA. Within 12 months of receiving an SDS with ESs!

15 Downstream user obligations 3. Recommend risk control measures for mixture uses (formulators) Options for communicating ESinformation for mixtures 1. Integrate information in main body SDS 2. Append safe use of mixture information 3. Attach relevant substance ESs as annex ECHA DU Guidance: The process should be efficient, risk-proportionate, and relevant and understandable to recipients.

16 The Detergents sector Professional Cleaning & Hygiene Broad range of products Many different product uses Many SME end-user customers NL: > SME cleaning companies

17 Common issues Several (end)uses not covered in Exposure Scenario s Formulator Unrealistic safe use conditions described Mixture SDSs often do not yet contain ES-related safe use information

18 Common issues Limited resources Many SME companies Often lack of sufficiently educated personnel End-user Determining safe use conditions difficult Own safety assessment needed Chemical/toxicological knowledge needed

19 Sector use maps Chemical Safety Assessment ES SDS SDS SDS Use information Identified Uses Manufacturer Sector use map SDS Safe Use Info Formulator Use information Sector association End-user Analysis of typical end-uses

20 20 Sector use maps Overview of typical uses within sector Describes actual use situation Duration? Ventilation? Protective equipment? Standardized format used by all sector associations

21 Example uses Example uses from detergents sector use maps: professional cleaning Diluting a product in a spray flask Max. 1 hour per day, no LEV possible, Spraying a product on a surface Max. 1 hour per day, no LEV possible, Brushing a product on a surface

22 Safe use of mixtures Communication to end-users: Safe Use of Mixtures Information (SUMI) Simplified, tailored communication on safe use of mixtures Based on analysis of typical enduses: Sector use maps

23 Safe use of mixtures Communication to end-users: Safe Use of Mixtures Information (SUMI) Simplified, tailored communication on safe use of mixtures Industry-wide harmonised format Based on uses specified in sector use maps Use-specific document One SUMI may be applicable for multiple mixtures Does not replace SDS SDS includes product-specific information

24 SUMI Format Mandatory SUMI content SUMI: Safe Use of Mixtures Information for end-users Sector_SUMI_code: Title of SUMI Sector logo General description of process covered May include use descriptor codes or reference to SWED Operational Conditions Maximum duration: Other: xx min. xxx Risk Management Measures Required RMMs, use of pictograms Reference to Section 8 of SDS for RMM specifications If applicable: any environmental measures Disclaimer Disclaimer on boundaries of SUMI use Sector_SUMI_code / version number

25 SUMI Format Optional SUMI content Good practice advice If relevant, applicable (sector-specific) good practice advice Use of pictograms when available Additional information on product composition To include references to other relevant sections of SDS or product label Sector_SUMI_code / version number

26 DRAFT A.I.S.E. SUMI example

27 A.I.S.E. SUMIs How to use A.I.S.E. SUMI as formulator? Define relevant uses of mixture Not classified? SUMI not needed. Check ESs of substances Substances contributing to classification Uses from sector use map covered? Select and send output A.I.S.E. SUMI-code in Section 1.2 of SDS Append applicable SUMIs

28 Use maps benefits Reliable, high-quality exposure scenarios Formulator Realistic use conditions described Standardized communication to endusers possible Safe Use of Mixtures Information (SUMI)

29 Use maps benefits Reliable, realistic conditions of safe use End-user Standardized, harmonized communication between suppliers SUMIs, tailored information for endusers Using the results of a chemical safety assessment done at manufacturer level

30 Summary Use maps improve upstream communication More detailed information on actual uses and therefore also downstream communication High quality, reliable exposure scenarios which enables safer workplaces, especially at end-user level. Using the assessment results from a more knowledgeable player in supply chain Acceptance from OHS authorities required

31 Thank you! Thank you for your attention Useful links: (A.I.S.E. Sector Use Maps)