COMMUNICATION ALONG THE SUPPLY CHAIN how downstream users can/should play their role?

Transcription

1 DUCC = platform for associations whose member companies use chemicals to formulate mixtures as finished products for end users (consumers and professional users) DUCC focuses on DU needs, rights, duties and specifities under REACH and CLP COMMUNICATION ALONG THE SUPPLY CHAIN how downstream users can/should play their role? Sylvie Lemoine (A.I.S.E. / DUCC) 18 April 2012 REACHCentrum conference, Brussels 1

2 Presentation outline Communication in the supply chain Supply Chain Communication (SCC): setting the scene Main requirements - reminder Main issues DU level SDS (with ES) + other information Annex:ES SDS M/I - Use and exposure information - Check RMM / ES : report if needed - Report new information Emerging solutions Use communication M/I DU SPERCs Learnings from 2010 preparing Implement RMM - Communicate SDS (ES) to his own DUs Annex:ES? SDS or DU s own Chemical Safety Report (only if used > 1t/y) 4 2

3 SCC Issues Supply chain communication goes multi-level, multi-player Supply chains are complex Flow of communication: need balance between top-down and bottom-up are needed Existing mechanisms are not obsolete, but they are not sufficient Safety Data Sheets Letters Contracts s Preparing 2013 Improvement areas: structuring and harmonising! Tools to use (including standard phrases) Formats and content 3

4 Use communication: Prior to registration Industry agreement on use communication for 2013 registrations DUCC, Cefic, Fecc and Concawe DU s right to make uses known in writing (Art 37(2)) 12 mths before registration deadline must be considered by registrant Provide sufficient information Upstream supplier, if not the registrant (e.g. DU, distributor), must forward upstream Top-down approach is preferred in practice Letter (for M/I) and fact sheet on use communication posted on Cefic s (and others ) websites Based on the 2010 experience, Industry has agreed to follow the top-down approach for use communication: Manufacturers/Importers to inform DU on the uses they intend to cover (e.g. via a link, website, reference to some use mapping from sector associations, ) Downstream users to check the available sources of information on uses No need for DU to pro-actively communicate common uses up the supply chain (e.g. those covered in the existing SDS, those already registered, those included in sector associations) 4

5 Industry agreement on use communication for 2013 registrations DUCC, Cefic, Fecc and Concawe When should the DU communicate his use(s)? If DU has a particular use If DU use(s) is missing in the communication received as soon as possible as soon as possible If DU does not receive any communication May 2012 (?) How? DU should provide sufficient information: use descriptors + OC/RMM (as a minimum) DU should communicate in a substance + supplier specific way Art 37(2) DU s right to make uses known 12 mths before registration deadline DO s and DON Ts for USE REPORTING DO s Before reporting Check current SDS Section 1 (uses, indication of later registration or exemption) When reporting (if needed) DON Ts When reporting Check supplier s website Contact supplier via indicated means (standard form, link, , ) Substance + Supplier specific reporting (e.g. only uses applicable to a given mixture) Use standard formats: DUCC UseR template + Use Descriptors (R.12 ECHA Guidance) Provide info on OC + RMM (as a minimum) Send tables with all possible combinations of uses/ud Change the use descriptors prepared by Associations 5

6 UseR Template... a simple and valuable tool! DUCC UseR: Description of uses Developed by DUCC for mapping and reporting uses Used by DUCC members to develop use mapping tables on behalf of their sector Number Code (for DU) (for DU) Short ES title Short description of process or activity Sector of use (SU) Process Category (PROC) USE DESCRIPTORS Article Product Product Sub-category category (PC) Category (AC) Environmental Release Category (ERC) To assist DU in informing their suppliers on their uses and conditions of use 1 Industrial Blending/dissolving/dispersion: mixing, dispersing, grinding - closed continuous process (no SU 10 PROC 1 N.A. N.A. N.A. ERC 2 In line with Cefic SES template Builds on the Use Descriptor System The information (use descriptors, OC/RMM) provided allows 1. Description of activities/uses of DU in a sector 2. Exposure assessment at Tier-1 level based on ECETOC TRA (Targeted Risk Assessment) Tool Each DU Association fills in the tables for its own sector, acting as a surrogate for individual companies (but not on behalf of companies) CEPE 1.1 T.B.D. FEICA I.2 manufacture of sampling) coatings and inks Receipt and storage of raw (PC5, 9, 18) materials: bulk raw material delivery (e.g. pigments/extenders) outdoor Air Fresheners aerosol (aqueous, non-aqueous, concentrated) for consumer use Consumer Use of Air Fresheners (timed-release aircare products aerosols, perfum in/on solid substrate (gel), candles, diffusers heated and electrical) Automated application of waterborne adhesive - Industrial SU 10 PROC 8b N.A. N.A. N.A. ERC 2 SU 21 N.A. PC 3 SU 21 N.A. PC 3 Aircare, instant action (aerosol sprays) Aircare, continuous action (solid & liquid) N.A. N.A. PROC 2 N.A. N.A. N.A. ERC 8a ERC 8a SU 3 ERC 4 PROC 8b N.A. N.A. N.A. (excerpt for illustration purposes) TIP UseR is also helpful for DU to check use coverage when receiving ext-sds/es 12 6

7 DUCC UseR Basic exposure information for ECETOC-TRA assessment UseR update in February to help in having more realistic ES!... New column Operational conditions: "concentration of substance in the mixture (w/w)". This is an optional parameter, which is substance specific, to be filled by each company, if considered relevant. The concentration should be indicated according to the exposure modifier of ECETOC TRA, i.e. by means of one of the following ranges: <1%, 1-5%, 5-25% or >25%. New version available at:

8 Use communication : Post- registration Use communication : In general (Extended-)SDS Section 1 Exposure scenarios M/I: Table of content at beginning of SDS annex, with list of ES Consistency with use mappings DU: Assess options in case of missing use Further communicate downstream Check consistency with use mappings Follow the Use Descriptor System Follow templates and models e.g. DUCC UseR template (for use mapping) and Cefic guidance Follow ECHA guidance (ES headings/format) Increase training/awareness of all actors 8

9 SPERCs: Why? Specific Environmental Release Categories First level Environment Assessment under REACH based on ERC s (R16) Release defaults set for ERC based emission estimates are worst case assumptions This may lead to overly conservative results An approach applying more realistic values (lower-tier assessment) while keeping standardisation appears reasonable SPERCs: What? Specific Environmental Release Categories Refinements of the ERC-based emission estimation define realistic default values (based on good practice information supplied by DU sector groups, trade associations). are documented in SPERC fact sheets Are included in ECETOC TRA v3 (environment) More than 170 SPERCs available SPERCs are an element of standardised supply chain communication of environmental assessments, e.g. in GES SPERCs have been extensively used for generating the dossiers of the 2010 REACH registrations SPERCs format and documentation are currently being reviewed for inclusion into CHESAR All published on the Cefic web site + available on DU association websites 9

10 SPERCs: example And now the SCEDs Specific Consumer Exposure Determinants SCEDs = SPERC-analogs for consumer assessment Refinements of exposure assessment for consumers based on ECETOC TRA consumers i.e. avoid having to run ConsExpo Refine default parameters of TRA consumers e.g. frequency of use, habits and practices of consumers DUCC coordinated project initiated A.I.S.E., CEPE, FEICA, FEA SCEDs to be made available for 2013 registrations Templates to be populated and made available by July 2012 Longer-term: include in Chesar 10

11 The ESCOM package Exposure Scenario COMmunication ESCom: standard phrases + IT standard (XML) for ES Communication between companies IT systems in the supply chain Longer-term horizon The ESCom package products ESCom XML 1.1 The Container for ES Info XML Schema-definition ESCom XML guidance document Technical documentation Example of an XML-File ESCom Standard-Phrases - The Content for ES Info Master-File with standard-phrases for ES (incl. phrase-codes) > 1900 phrases Guidance document for phrase development > 1000 downloads since May

12 2. The ESCOM package objectives ESCom should be applicable for the downstream communication of ES over the whole supply chain Made available for free (English only) Aligned with BDI EuPhraC phrase system for SDS 2. The ESCOM package Industry s vision EsCom Phrases GES SpERC Will only work if all players in the supply chain apply XML and phrase standards IT providers to develop interface to implement it into their SDS softwares M/I Exposure Assessment Tool DU Scaling Tool Formulator Mixture Assessment Tool Should be used for the entire ES, no/limited for free text Will take some time to implement in the supply chain and to have all IT systems upgraded 23 Industry standards Data Std Chesar TRA? ESCom XML Scaling Tools Under Development ESCom XML Tools for Mixture Assessment Under Development ESCom XML 12

13 2. ESCOM: next steps Conclusion: we need standard and pragmatic solutions ESCom 2 being set up ( ): Cefic / DUCC / IT providers Alignment/compatilibility with Chesar 2.0 (ECHA) stable XML standard Maintenance and update, focus on standard phrases Standard phrase maintenance Procedures and tools to manage / download We are still in a learning phase, but we need to build on 2010 learnings Good supply chain communication and discipline will help in generating realistic exposure scenarios Standardisation via IT tools and harmonised templates / formats: use ES format of ECHA guidance Build on existing tools, guidance and emerging solutions Further improvement of assessment tools Need to optimise communication flows (top/down vs bottom/up) Training of all players is needed 13