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.