Improving Communication of REACH/CLP Information in the Supply Chain

Transcription

1 Improving Communication of REACH/CLP Information in the Supply Chain ChemSpec June 2015 Bridget Ginnity European Chemicals Agency Can information from REACH/CLP help chemicals be used more safely? Exposure scenarios experience, challenges and solutions Formulators their vital role Information in the supply chain the goal Information from REACH/CLP what is available to support environmental and health and safety activities The plans and the progress 2

2 Exposure Scenarios New feature introduced in REACH Communicate conditions of use that ensure control of risks from exposure to a substance during manufacture and use Annexed to safety data sheet for substances Based on the exposure assessment carried out for REACH registration (>10 tonnes/year) 3 Exposure Scenarios (ES) Lessons learnt Recipients need exposure scenarios to be: relevant and realistic easy to navigate easy to understand Suppliers need exposure scenarios to be: easy to generate easy to translate 4

3 Finding solutions the framework CSR/ES Roadmap a joint action plan towards Exchange Network on Exposure Scenarios (ENES) a working community of stakeholders ( Industry ECHA Member States 5 ENES/Roadmap aim: to make information in ES more relevant and realistic Chemical Safety Assessments based on actual conditions of safe use Sectors describe how they use a substance using excel based use maps Registrants base assessments on use maps Use maps include elements for communication in the exposure scenario Upstream communication is vital.. Sector use maps 6

4 ENES/Roadmap aim: To make ES s easier to generate and translate ECHA s tool for CSR: Chesar. Generates CSR and ES for communication ESCom project catalogue of standard phrases XML schema to send Exposure Scenarios electronically: ( cross-stakeholder, including IT companies 7 ENES/Roadmap aim: To make information in ES s easier to find and understand Suppliers provide ES with: Harmonised format (titles, sections, content in sections etc.) Table of contents Relevant exposure scenarios only Examples and annotated templates available to help suppliers and recipients 8

5 Most chemicals used are mixtures ENES/Roadmap aim: To support processing of information at Formulator Level Communicating information on uses upstream Classification, labelling and packaging of mixtures Communicating information on safe use downstream 10

6 Formulating mixtures for end users Supplier 2 Substance A Supplier 1 Substance A Supplier 3 Substance B and Mixture C What to communicate? And how? Mixture D (=A +B +C) 11 Identify information to communicate - bottom up approach Existing conditions of safe use identified within sectors Provided as Safe Use of Mixtures Information (SUMI) Harmonised template Uses clear language, pictograms, in sector terminology Formulator cross checks covered by supplier ES SUMIs expected end

7 Safe Use of Mixture Information (SUMI) Mandatory SUMI content Optional 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 Maximum duration: Other: Operational Conditions Risk Management Measures xx min. xxx Required RMMs, use of pictograms 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 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 Sector_SUMI_code/ version number NOTE: This format is still subject to(minor) editorial changes. 13 SUMI: Example AISE Note: Thisexampleis a draft and subject to change. 14

8 Identify Information to communicate top down approach Industry sector developing a common methodology to identify the lead components for various routes of exposure This identifies which OC/RMMs to communicate This is communicated as safe use information on mixture Draft guide published and testing July/August Aim to finalise methodology Q Effective communication in the supply chain the goal

9 Information for CSR upstream communication CSR Registrants SCED Consumers Sector use maps SWED Environment Workers SpERC Relevant information on conditions of use that can be readily processed for registrants Downstream users / sector organisations 17 Information from CSR - downstream communication SDS Substance Registrants ES Clear and relevant information on conditions of use for formulators for end users SDS mixture SUMI End users 18

10 The communication cycle Registrants SDS Substance ES ENES CSR/ES Roadmap SDS mixture SUMI Downstream users / sector organisations 19 Information on chemicals to support Environmental Health and Safety (EHS) activities How is it classified? What is it used for? Likely to be restricted? The safety data sheet is the primary source of information on chemicals The ECHA website and other sources can provide useful additional information 20

11 Databases on ECHA website Registered Substances >13,000 substances registered C&L inventory >120,000 substances notified Regulatory status, and databases from other regulations and previous chemicals legislation 21 Substance information from REACH registration (New format on ECHA website later in 2015) Infocard gives simple high level overview of a substance Understandable to the broadest possible audience More detailed profiles will also be available 22

12 23 And the potential benefits.. Positive effect on safe use of chemicals improved information in supply chain communication increased knowledge of how substances/mixtures are used better integration of REACH/CLP with other environmental health and safety obligations Positive economic effects for business improved communication within supply chain product stewardship consumer confidence Reviews are reporting benefits and challenges 24

13 Can information from REACH/CLP help chemicals be used more safely? Exposure scenarios improved content, format and automation supports communication Formulators they are working to communicate the relevant information in an understandable way Information in the supply chain use maps lead to better information in, and result in better information out Information from REACH/CLP a lot is available on ECHA website to help Environmental Health & Safety activities Follow the developments: 25 Thank you! bridget.ginnity@echa.europa.eu Subscribe to our news at echa.europa.eu/subscribe Follow us on Follow us on Facebook Facebook.com/EUECHA