Helsinki- The European Chemicals Agency published its guidance for downstream users on how to prepare to implement REACH- the new European Union regulation on Registration, Evaluation, Authorisation of Chemicals - on 1 Feb 2008.
This 162-page document describes the roles and obligations of downstream users, and advises them on how to prepare for the implementation of these new regulations for the chemical industry in Europe. But luckily, ECHA says it does not expect downstream users to read the entire document: they can skim through it to find the information relevant to their own situation.
A downstream user is defined as someone who uses a substance, either on its own or in a preparation, in the course of his industrial or professional activities, according to this document.
Many different types of companies can be downstream users, ECHA points out, including formulators of preparations, producers of articles, craftsmen, workshops and service providers or re-fillers, the ECHA document points out.
And it adds that the guidance is also aimed at others in the supply chain, who are not downstream users or manufacturers and importers, but still have obligations under REACH. This includes distributors, retailers and storage providers.
Introductory chapters give the background (overview of REACH, roles and obligations of downstream users and how downstream users can prepare for REACH) and direct readers to the main chapters of the guidance that help them to meet those obligations.
The main chapters provide further detail to help users to meet their specific obligations under REACH.
The guidance is structured so that users only need to refer to the chapters that are relevant to them, and they are led through the document by a series of questions.
1. What is REACH and what does it mean for me? chapter 1.
2. Am I a downstream user and what are my obligations? chapter 2
3. How should I prepare for REACH? chapter 3
4. What should I do when I receive information from my suppliers? chapter 4
5. What if the information includes an exposure scenario? Go to chapter 5
6. What if the exposure scenario does not cover my use? chapter 6
7. How do I prepare a downstream user chemical safety assessment? If you decide to make a downstream user chemical safety assessment, go to chapter 7
8. How do I inform my supplier of my use? chapter 8
9. What information will my supplier need and how can I get it? chapter 9
10. What if I have new information on substance hazards? chapter 10
11. What if I have information that calls into question the risk management measures in the safety data sheet or exposure scenario? chapter 11
12. What is authorisation and what does it mean for me? chapter 12
13. What are restrictions? chapter 13
14. I am a formulator of preparations - what do I need to do? chapter 14
15. I am a distributor - what are my duties under REACH?chapter 15
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