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Data Exchange & Uses

The SIA fully supports the process adopted across the EU Trade Associations. This process, which makes use of Generic Exposure Scenarios (GES), was led by the major European manufacturers of solvents. It was the principal way that downstream uses (applications) were captured and risk assessed.

All the major European Trade Associations covering uses, or applications, supported this approach as the most realistic way to manage communication up/down the supply chain.  The process progressed reasonably well, but was not without problems. The ECHA Use Descriptor System was not particularly easy to use and was open to subjective interpretation, resulting in the same end-use being described in a number of different ways. A number of Generic Exposure Scenarios were developed and the Hydrocarbon Solvents Consortium has published on its website the end-uses that its members will be including in their dossiers.  This can be viewed here.   Suppliers and Trade Organisations can help with concerns about applications, and their exposure scenarios.

It is now clearer how information on uses and applications will be managed up and down the supply chain.  Suppliers need to convey how their products may be safely used, by means of the extended SDS. But, before then, customers should have exercised their right to communicate their use information to the supplier, i.e. the manufacturer or importer. Products with a 30th November 2010 registration deadline required users to notify suppliers of their intended uses before 1st December 2009. However, as long as an exposure assessment can demonstrate that an end-use is not harmful to humans or the environment, the Chemical Safety Report can be revised at any time and an updated dossier submitted to ECHA.

Suppliers are not obliged to register every use communicated to them by customers.  They can choose not to support a use for reasons such as health or the environment, but they will need to state their reasons to the customer and to ECHA.

Hence, customers may find they have a decision to make. They will need either (a) to find a supplier who will support their use, or (b) to develop their own exposure scenario, or (c) to cease using the product in the unsupported use.  However, the number of solvent end-uses that will not be supported is likely to be very small.

The process of the communication of customers’ uses to suppliers in the chemical industry has been improved. Led by CEFIC, DUCC, ATC and others, a common communication process has been introduced, whereby a supplier may proactively notify a customer of the supplier’s supported uses. The dialogue started, the customer can respond with other uses of importance to them.

It will benefit customers to understand how REACH requires uses to be described. The REACH use descriptor system asks that a “use” is described by Sector of Use, Product Category and Process Category.  This information is detailed in the ECHA Guidance on information requirements and chemical safety assessment, Chapter R.12: Use Descriptor System, available here.

In some circumstances companies outside (or indeed inside) the EU have appointed “Only Representatives” to act on their behalf to support administration and consortia formation. Once Pre-Registered, a company will know the identities of the initial members of that SIEF – those companies who have registered the same substance.

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