ECHA newsletter about uses

LESS THAN TWO MONTHS LEFT TO DEADLINE FOR USERS OF CHEMICALS TO INFORM SUPPLIERS

There are less than two months left for the Downstream Users of chemicalsubstances to inform their suppliers of the use they make of the substance.The deadline, 30 November 2009, applies only if the substance needs to beregistered before 1 December 2010.

As a user of a chemical (Downstream User) you should inform your suppliers about your useof a substance if you want the supplier to consider your use in relation to his registration.Before informing your supplier, you are advised to check the use mappings prepared by yourindustry association, and/or any communication from your supplier about the uses he intendsto cover.
Alternatively, you can assess later the use and fulfil the related duties yourself.

The advantage of communicating your use in time to your supplier is that your conditions ofuse are then more likely to be covered by your supplier’s Exposure Scenario, as theregistrant of the substance will have to take account of your use in preparing the ChemicalSafety Assessment. You then can expect your use to be an identified use and have anExposure Scenario covering your conditions of use, unless the registrant cannot support theuse. If the registrant cannot support your use for reasons of protection of human health or theenvironment, both the Downstream User and the European Chemicals Agency need to benotified.

If you do not communicate your use and it is not covered by your supplier’s ExposureScenarios, you will eventually need to prepare a Chemical Safety Assessment yourself oncethe substance has been registered.You need to provide your information in writing to your supplier on both the use and theconditions under which the substance is used.

ECHA has published a Fact Sheet that provides background information and further detailsabout the Downstream Users’ right to inform their suppliers of the use they make of thesubstance (see further information).

In addition, there is REACH guidance available, andtools have been developed by industry to help you. Your industry association may also beable to assist.

Links to background information are available overleafECHA/NA/09/19 News Alert:

Further informationREACH GuidanceGuidance for Downstream Users (chapters 4, 6, 7 and 8):http://guidance.echa.europa.eu/docs/guidance_document/du_en.htm?time=1254330774

Guidance on information requirements and chemical safety assessment Chapter R.12: Usedescriptor systemhttp://guidance.echa.europa.eu/docs/guidance_document/information_requirements_r12_en.pdfREACH

Fact SheetDownstream Users – How To Make Uses Known To suppliers:http://echa.europa.eu/doc/reach/reach_factsheet_du_en.pdfIndustry guidance and tools.

The Libraries section of the Cefic (European Chemical Industry Council) website contains an overview of Downstream Users’ use mapping activities, and links to the Downstream Users’tables of uses can be consulted at:http://www.duccplatform.org/activities/use_and_exposure_info.htmlhttp://cefic.be/en/reach-for-industries-libraries.html

Guidance on managing use communication in the supply chain developed by Cefic can beconsulted at:http://cefic.be/Files/Publications/Guidance_Use_and_ES_dvlpt_and_SCCm.dochttp://cefic.be/templates/shwPublications.asp?HID=750&T=806

The Downstream Users of Chemicals Coordination group (DUCC) member associations areusing the DUCC template for describing uses and providing basic Operational Conditions /Risk Management Measures. They have worked with Cefic to ensure respective templatesare complementary.

The DUCC UseR template (empty) can be found on the recentlyupdated DUCC website at:http://www.duccplatform.org1ECHA does not endorse tools or guidance developed by industry. Please contact the relevant industryassociation for further information about these tools. And keep also in mind that your own industry associationmay have additional guidance and tools.

Authority checks Only Representatives in Hungary

The authority started to check the compliance with REACH regulation in Hungary.
On the 18th of September I passed the authority checking as a REACH Only representative.

They checked:

1. the pre-registration reports
2. up-to-date information on customers sold to
3. Hungarian and English MSDSs
4. letter to the customers about appointment of an OR

The Hungarian competent authority is good at REACH, they got a good training.
What about the checking of REACH in other EU countries? Please share with us your experience.

Agnes Botos
REACH consultant
Phone: 36- 1 -9502710
Mobil: 36-20-2205737
Skype: agnes.botos
E-mail: agnes.botos@gmail.com
Link: http://www.reachexpert.eu/

REACH database -REACH softwares

Dear all,

I like to follow what kind of REACH softwares are available in the market, since many times I need to recommend a good REACH software for my customers.
I had the opportunity to see a presentation from a French company called RimaOne this week.
After the presentation I felt that their software is perfect for bigger companies.
The program looked quite user friendly, and they are able to fit it to the company's demand in few weeks, which is a huge advantage. If you are struggling with collecting uses , or need to send and save many customer questionnaires, then this tool looks prefect for you. Anyway, please check this link if you are interested in: http://rimaone.free.fr/R1_Demo%20SCC(No%20Sound).wmv and I will send you the contact person name at Rima One.

Please let us know if you know other good REACH software companies as well. Lets put them to this blog so my customers can choose.

6 REACH guidance available in local language

In a further 21 EU languages ECHA has published guidance on the following 6 documents:

INFORMATION REQUIREMENTS AND CHEMICAL SAFETY ASSESSMENT:
1. Part A: Introduction to the Guidance Document Provides an introduction to the guidance for conducting the chemical safetyassessment and preparing the chemical safety report for substances manufactured orimported in a quantity of 10 tonnes or more per year.

2. Part D: Exposure Scenario Building Details how to develop exposure scenarios and related exposure estimation.

3. Chapter R12: Use Descriptor System Gives a brief general description of identified uses and how to give exposure scenarios a short title.

4. GUIDANCE ON REQUIREMENTS FOR SUBSTANCES IN ARTICLES This document assists producers and importers of articles in identifying whether they have obligations under REACH.

5. GUIDANCE ON REGISTRATION This document describes when and how to register a substance under REACH. It consists of two parts: one on Registration tasks and obligations and the other on the preparation of theRegistration Dossier.

6. GUIDANCE FOR DOWNSTREAM USERS – LINGUISTIC UPDATE PUBLISHED IN THE INTERNET This document describes the roles and obligations of downstream users, and advises them on how to prepare for the implementation for REACH.

It is much faster to read them in your native language. You can find them here:
http://guidance.echa.europa.eu/guidance_en.htm

Agnes Botos
REACH consultant
Phone: 36- 1 -9502710
Mobil: 36-20-2205737
Skype: agnes.botos
E-mail: agnes.botos@gmail.com
Link: http://www.reachexpert.eu/

Lead registrant conference 2009 Brussels: presentations

Dear all,

I participated in the lead registrant conference organized by ECHA in Brussels on the 11th of September. Over 500 companies – Lead Registrants and Candidate Lead Registrants –joined together on that conference to share best practice.

It was possible to ask questions to ECHA and to industry representatives in the conference. There was a separate meeting room during the breaks where at least 10 ECHA employees tryed to answer the company specific questions. It was possible to ask questions from Cefic as well.

There were many useful presentations. I add here the link where you can find them.

http://ec.europa.eu/enterprise/sectors/chemicals/reach/events/index_en.htm#h2-reach

If you have time you can see the web streaming of the workshop:http://webcast.ec.europa.eu/dgenttv/portal/index.html

I will write you more details ( summary) about the presentations in my autumn newsletter. Please ask me to send you the actual newsletter.

Agnes Botos
REACH consultant
Phone: 36- 1 -9502710
Mobil: 36-20-2205737
Skype: agnes.botos
E-mail: agnes.botos@gmail.com
Link: http://www.reachexpert.eu/

www.reachexpert.eu

My name is Agnes Botos. I have a Master’s Degree in Chemical Engineering and a 2-year post-graduate degree in Environmental Law. Currently I work as a REACH and GHS consultant.

Since I started my own business I have supported more than 50 Hungarian and foreign companies to understand the REACH regulation and to complete the pre-registration on time. In 2009, my most important task is to prepare registration dossier for EU and non-EU companies. I learned how to prepare a registration dossier with IUCLID 5 program in Brussels at REACHCentrum and I participated in the lead-registrant workshop organized by ECHA in 2009 September.

According to my experience I provide support primarily to those REACH responsible, who do not have enough time to read the extensive REACH regulation and related guidelines in English, have difficulty preparing the Registration Dossiers, communicating in the different SIEFs and as a result they are unable to make good strategical decisions related to REACH. Me and my partners are following all changes related to REACH in order to provide you with up to date information and save your company time and money. My services guarantee 100% compliance with the complicated REACH regulation, which also means avoiding any possible fines and penalties.

Prior to starting my own consultancy, I worked for 10 years as an Environmental Health and Safety engineer in the European Central Environment Health and Safety Department of General Electric Company, both in Hungary and the United States. Since 2006 my main focus has been REACH, the new European chemical legislation. I participated in several REACH conferences in Brussels, and I experienced first hand the difficulties of REACH implementation into practice, as well. I represented a multinational company in various pre-SIEF discussions.
Since September 2008, I have been a part-time PhD student at the Central European University, where my dissertion topic is ”Interaction of REACH and TSCA reform ”.I have a close working relationship with several Hungarian and European REACH experts, who willingly provide their perspective and added expertise for my consultancy.

If you are a REACH responsible, you will find useful information in my blog and my newsletter, which will help you to find much simpler the compliant with the REACH regulation.