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Technical
Guidance Document (REACH Implementation Project 3.5) on requirements
for downstream users - prelimimanry study
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Main commissioner:
European Commission
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Carried out by:
Antonia Reihlen, Institute for Environmental Strategies, Ökopol,
Hamburg, Germany
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In co-operation with:
Danish Toxikology Center , DK (Project leader and direct commissioner);
DHI water and environment, DK; BRE Environment, UK; Baltic Environmental
Forum Latvia, LV; Risk and policy analysts, UK
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Duration:
March 2005 - December 2005
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Background |
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In October 2003 the EU Commission has published a proposal
for a New European Chemicals Policy (REACH = Registration,
Evaluation and Authorisation of Chemicals). Downstream
users of chemicals will have to comply with various new requirements
when the regulation enters into force, of which the most important
ones are described here: |
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Safety data sheets of dangerous substances
and preparations will be accompanied by an Annex which contains information
on the safe use of the chemical. This description of safe use will
contain among other information on the identified use, the operational
conditions of use and risk management measures to be applied. Downstream
users of dangerous substances and preparations will have to assess
whether their use is covered by the so calles exposure scenario communicated
in the Annex of the SDS. |
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Furthermore, downstream users will have to check if
the substances as such or contained in preparations falls under the
authorization procedure under REACH or if they are banned or use restricted. |
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Compliance with these requirements, as well as ensuring
that substances, essential to the own processes remain available on
the market can only be achieved if communication and cooperation along
the supply chains is enhanced and improved in the future. This is
hindered by various factors, of which business secrets and a common
understanding of the "language" used by different actors
to
communicate about chemicals risks are only the most obvious ones. |
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The EU-Commission prepares the implementation
of the REACH regulation by launching several REACH implementation
projects (RIPs) the goal of which is to develop guidance for industry
and authorities.
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Objectives |
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The goal of this scoping study is to elaborate
which type of guidance and tools are necessary for the different types
of downstream users to enable them to fulfill the requirements of
the future legislation. |
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The expected result of the project is a proposal for a structure
of a guidance document for downstream users. This includes a decision
tree for the identification of roles and responsibilities of the
various actors as and flow diagrams outlining the work process to
fulfill the requirements. Parts of these flow diagrams will be worked
out in more detail. Another result of the project will be recommendations
on how to proceed in the development of the guidance. The focus
of the guidance lies with the communication aspects of downstream
users.
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Tasks |
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The scoping study is carried out in three
phases: |
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- Phase: Evaluation of existing experiences on roles and responsibilities
of various actors in the supply chain related to the safe use
of chemicals and the fulfillment of existing requirements. This
includes an analysis of structures of supply chains and companies.
- Phase: Development of a guidance structure. Here, downstream
users are guided in finding their roles and related requirements.
For the different tasks, work flows will be outlined in form of
flow schemes. Furthermore, the single working steps to be carried
out in order to fulfill the requirements are outlined. It will
be pointed out, for which of the tasks instruments are needed.
- Phase: the guidance structure and flow schemes will be discussed
and tested in three example supply chains. The draft proposal
of these documents will be revised according to the experience
gained in this project phase.
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Contact |
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Dirk Jepsen |
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