What are the REACH obligations of downstream users?
As a DU, you must identify and apply the appropriate measures to control risks associated with the use of chemicals. In practice, this involves the following steps:
- You must check whether your (category of) use has been covered by the SDS provided to you by your supplier. On some SDSs this use may be described in a very generic way (e.g. ‘For industrial use’). On others, especially on extended SDSs (e-SDSs), which are accompanied by one or more Exposure Scenarios (ESs), the use may be defined in much more detail (e.g. ‘Professional uses: Public domain, Product category 35 – Washing and cleaning products’).
- Where RMMs are prescribed on the SDS, you must implement these. Depending on the hazard profile and the identified use of the chemical, this may involve the ventilation of the workspace, monitoring of emission concentrations or the use of personal protection equipment (PPE) such as protective gloves, goggles or clothing.
- If your use has not been covered by the SDS (for example if you are a professional painter, and the SDS of your solvent only covers industrial use in a closed batch process), you must:
- Contact your supplier and inform him of your use. The supplier has to assess this newly identified use within one month or before the next supply, whichever is later. Incidentally, in case your particular use of the chemical is considered a risk to human health or the environment, the supplier may decide to define yours as a “use advised against”. It this case, you will have to use an alternative product.
- Alternatively, you may find another supplier who provides the substance with safety documentation that covers your use, or you may prepare a Downstream User Chemical Safety Report (DU CSR) yourself.
Do you place substances or mixtures on the market?
If you place substances, mixtures or articles on the market, you must not only consider the activities within the boundaries of your own organisation, but also those of your customers. This means that you must identify your clients’ uses of the chemicals you supply further downstream, and check whether these uses have also been covered on in the exposure scenarios attached to your supplier’s SDS (step 1). If this is not the case (for example if you produce household detergents for the consumer market, and the exposure scenarios exclusively cover the use of the substance in a professional setting), you must inform your supplier, or perform a Chemical Safety Assessment for this use yourself (step 3). Finally, you must make sure your products are classified, labelled and packaged in accordance to CLP and that you provide your customers with a product SDS.
Our downstream user services include:
- Identification of your specific REACH obligations
- Implementation of Risk Management Measures (RMMs)
- Downstream User Chemical Safety Report (DU CSR)
- Safety Data Sheets (SDSs)
- Workplace Instruction Cards or Safety Instruction Cards (WICs/SICs)
- Supplier communication support