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Posted By Christopher Boocock
As a "Downstream User" of Chemicals, and having read the information on the HSE Website - including the DEFRA & EC's presentation, I'm unclear as to whether or not I need to undertake any more than the risk assessments required under COSHH Reg.6 taking into account the information on the Material Safety Data Sheets.
I started to look at the Regulations themselves but they run to 849 pages!
I'd be grateful for opinions, advice & experience.
Many Thanks
Chris
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Posted By Darren J Fraser
Hi Christopher
As I understand REACH
You need to ensure that your chemical supplier is aware of the process you have that uses that particular chemical.
If the process is not declared and recognised, REACH would prevent the sale and use of that chemical for that particular application.
AS regards COSHH RA, my understanding is that the above will be taken into account, and may in fact identify hazardous that have previously been unforeseen.
I stand to be educated by fellow users, with a greater understanding of REACH, in any areas that I am incorrect.
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Posted By Christopher Boocock
Darren.
Thanks - most of the chemicals we use are commercially available greases, oils, adhesives, jointing compounds etc. - The usual sort of stuff found in a Engineering Workshop.
However, we do have water treatment chemicals for boilers & cooling towers - but that are supplied by the manufacturer for a specific purpose - e.g. oxygen scavenging, biocides etc.
So I would have thought that if we "do what it says on the tin" do we have to do anything extra?
Maybe just confirm to the supplier that that is what we are doing?
Chris
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Posted By Chris Packham
There are still many grey areas in REACH and no-one at the moment can be completely certain as to how REACH will finally be applied. However, at present the situation as I understand it is:
a) The manufacturer of a substance must register this. He must produce a Chemical Safety Assessment. He must also provide the downstream user, i.e. the person he supplies with an Exposure Scenario and Risk Management Measures.
b) The downstream user may also be a manufacturer. For example, if he purchases substances and formulates a preparation, then he has also to complete a Chemical Safety Assessment and provide his downstream user also with Exposure Scenario and Risk Management Measures.
c) If the downstream user decides that the Exposure Scenario is not relevant to his particular application, then he has the right to submit a document to the supplier for the registration of his application as a new "use".
All of this has to be recorded in Helsinki (as and when the new authority is up and running!)
If the Exposure Scenario is not relevant the downstream user may have to submit a Chemical Safety Report direct to Helsinki!
REACH also relies upon "Derived No Effect Levels". Since there is currently no way we can produce any meaningful such devels for skin exposure, it is uncertain how we will be able to apply REACH for skin exposure.
Confused?
So is everyone else that I have met so far who, like me (as Chair of the BOHS Special Interest Group on Hazardous Substances and a member of the Chemical Hazards Communication Society), is trying to make sense of REACH.
Oh, by the way. REACH may run to 849 pages, but the guidance documents for REACH have already exceeded 3,5000!
Chris
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