Roles and obligations Antonia Reihlen Ökopol GmbH
Introduction The role of roles under REACH Types of roles and related obligations How to identify roles of the company
The role of roles REACH aims to ensure protection of humans and the environment from chemical risks and to enhance competitiveness and innovation in Europe Both goals require a common approach to identify, communicate and control risks from chemicals All actors in the supply chain and the authorities have their role to play
The role of roles - 2 Roles are defined in relation to substances as such, contained in preparations or contained in articles Each actor can have several roles, depending on the type of substance and where it is sourced from Obligations are defined depending on the role and the specific substance, respectively
Types of roles 15.08.2006 Manufacturer + = Manufacturer Manufacturer
1. REGISTRATION > 1 ton/year Agency M > 10 ton/year CSR > 10 ton/year Substance Producer 2. COMMUNICATION SDS Supply chain > 10 ton/year SDS Painter
Types of roles 15.08.2006 Importer EU I Substance Preparations Article
Importers have the same obligations as manufacturers however, there are practical differences: Chemical safety report misses manufacturing and Imported substances (in preparations) need to be identified and quantified to determine if tonnage threshold is exceeded.
Types of roles 15.08.2006 Downstream user DU Professional I M DU DU Formulator Article Producer
SDS SDS EXPOSURE SCENARIO Information DU CSR Conditions of?! use = RMM Formulator Implementation
SDS DU New hazard information Risk Management Measures DU Formulator SDS SDS
Types of roles 15.08.2006 Article producers Article producers may (!) have to Register substances intended to be released or Notify the content of specific substances Communicate the content of specific substances in DU the supply chain Article Producer
Types of roles 15.08.2006 Distributor DEFINITION A distributor is any natural or legal person established within the Community, including a retailer, who only stores and places on the market a substance, on its own or in a mixture, for third parties. Distributors have to forward any information they receive from up or down the supply chain
Role identification Roles depend on the specific substances Structured approach = chemicals inventory Input = purchased substances, preparations, (articles) Name, type, identification (substance or preparation?) Source (own manufacture/import/eu, distributor/manufacturer) Output = manufactured products = substance or preparation or article Identification of M/I/DU/D and obligations
Tools for role identification ECHA has produced a Navigator tool Interactive dialogue leading to identification of obligations linked to respective guidance (where available) http://reach.jrc.it/ Furthermore, flowtext on REACH REACH implementation project on developing guidance for downstream users (RIP 3.5) Separate document on roles of downstream users to be published soon (more detailed) http://reach.jrc.it/guidance_en.htm
HSE has web-pages on REACH 15.08.2006 Tools for role identification Flow text on roles and obligations with links to further information http://www.hse.gov.uk/reach/role.htm Official helpdesk Questions can be asked http://www.hse.gov.uk/reach/helpdesk.htm E-learning tool on REACH http://ereach.dhigroup.com/index.htm