As a downstream user the manufacturer should be asking how you are using their product. The best way of providing this is via a coshh assessment. Exposure scenarios will be included in sds' but they will limited until the sief has agreed what goes in it. In the long run the data sheets should improve as there will be greater standardisation of data sheets from a wider knowledge base.

On the plus side everybody will now have a full inventry of the chemicals they have in order to determine what SVHCs, bioaccumulators, endocrine disruptors etc they are using. Not a specific requirement but if you don't know what you have you don't know what you should be doing.

I would not claim to be a REACH expert, but my understanding of REACH is that it is concerned with single substances. Those placing these on the market have to produce a safety data sheet, attached to which will be exposure scenarios covering each use for which their substance has been registered. The downstream user, who could be a formulator, might take several substances and from these produce a mixture (note mixture not preparation!). He must produce a safety data sheet for his mixture, but need not produce exposure scenarios, merely take the relevant ones from each of the constituent suppliers and attach them to his safety data sheet. The end user will need to consult these (which hopefully will agree with each other!) and ensure that his use is covered by them. If not, then it will be illegal for him to use it for this use. Considering how few safety data sheets are actually correct, I do have my doubts about the quality of the (much more complicated) exposure scenarios we will be seeing! Some groups are looking at producing "generic exposure scenarios". A recent article in the Annals of Occupational Hygiene covered this and included an example of how such an exposure scenario might look. I had great difficulty understanding exactly how to interpret this, so what chance there is of a manager of, say, a small car body repair shop understanding it is open to some speculation. My personal approach is to ignore this paperchase and fall back, as I have done for years, on section 6-1 of the Health and Safety at Work Act 1974 which requires the supplier to provide such information as to enable his product to be used safely for the purpose for which it has been supplied. Much simpler and more direct, as the end user requires this information from the supplier (e.g. formulator, distributor), ignoring the complex supply chain and the information that he may receive from the suppliers of the individual substances via the formulator. Chris

Ken I wish I knew! When I go back on behalf of a client to their suppliers to request section 6-1 information this is usually countered by: "But we have let you have a safety data sheet". When I point out that this is not what the section requires, then there is frequently confusion. Many have never seen section 6-1. I doubt whether some have even seen a copy of the Act. Most do not have the knowledge to provide this information. Often, when the information does arrive, it is obvious that the person who had prepared it did not understand what was required of them or has simply got it wrong. The whole situation is, in my view, completely unsatisfactory and I do not think that REACH will benefit most end users, other than to add considerably to the content of their filing cabinets. Earlier this year I visited a company who had arranged for a large and well known health and safety consultancy to provide them (at not inconsiderable cost) with their risk assessments. When examined it turned out that they had sent their safety data sheets to the consultancy who had then issued risk assessments without any factory visit or other data. In other words, the 'risk assessments' were merely a regurgitation of the safety data sheets with a few extra bits of information added. With friends like these . . . Chris

Manufacturers do not necessarily have to supply a sds. They can comply by providing information to enable the end user to use it safely. So the link to the HASAWA is still there. Manufacturers don't just register single chemicals they must consider articles and risks associated with them in use or disposal. COSHH still plays an important part in the control of chemicals and end users should be checking that the use of their chemical is registered with the manufacturer or SIEF. That is unless it's commercially sensitive in which case you can register the use yourself but must provide all the info to ECHA yourself. A very very expensive process.