We are receiving more and more safety data sheets with DNEL & PNEC following REACH registration of substances. I know we have 12months(from receipt of SDS) to implement risk management measures for workers and environmental exposure based on new available data.

There are two programs to tackle this available: EASE for making a simple assessment of worker exposure and EUSES for predicting environmental impact. I need a simpler way to assess these RMM’s.

I need a clarification on whether it is only when I receive e-SDS that I have to analyse workers exposure/environmental impact or is it also applicable to these new SDS’s with REACh registration number on them. Attached is an example of an SDS.

Any comments appreciated

It is my understanding that, where a substance has both a WEL and a DNEL, we have to control to the lower of the two; please tell me I am wrong!

LB

WELs are only relevant for inhalation exposure. When submitting their chemical hazard assessment for REACH the registrant is required to provide DNELs for inhalation, ingestion and skin. However, as far as I am aware there is no provision in the regulations to require workplace exposure to be limited to the DNEL. Indeed, as far as skin is concerned, this is impracticable.

“However, there is no scientific method of measuring the results of the body’s exposure to risk through dermal contact. Consequently no dermal exposure standards have been set.”
from “Occupational skin diseases and dermal exposure in the European Union (EU-25):policy and practice overview - European Agency for Safety and Health at Work

Back in the 1990s the Dermal Exposure Network of the EU (of which I was a member) spent 3 years looking at this and concluded that creating exposure limits for skin is simply not possible.

Consider also that the DNEL only applies to the actual substance. As soon as this is mixed, diluted, etc., then the DNEL is irrelevant as any exposure limit would have to relate to the mixture.