The purpose of REACH is to achieve a high level of protection of human health and the environment. Amongst other aspects, this Regulation defines the obligation to register and provide information on all chemicals placed on the EU market. Under REACH, registration is the duty of the supplier of the substances, but a good quality registration needs to be based on updated and reliable information that describes how products containing those substances are used.
A.I.S.E. is an accredited stakeholder organisation of the European Chemicals Agency ECHA and works together with it and all interested parties towards successful REACH implementation. We are a leading member of DUCC, the Downstream Users of Chemicals Coordination group, and also participate in several working groups of Cefic, the chemical industry association.
REACH Supply Chain Communication
To achieve the objectives of REACH, good communication between the different actors of the supply chain is necessary, meaning between registrants and downstream users.
The registrants are responsible for the registration of the substance – registrants are primarily the manufacturer or importer of a substance. The downstream users are the industries that use a substance, either on its own or in a mixture during their industrial or professional activities, such as to produce detergents or in cleaning and disinfection of surfaces at hospitals to prevent contamination.
Typical examples of information transferred between these supply chain actors are use maps and exposure scenarios.
- Use maps are created by downstream users to provide information to registrants about how their products (such as a cleaning or maintenance product) are produced and how they are used by end-users. This information is valuable for registrants since it needs to be considered in their registration dossier.
- Exposure Scenarios (ESs) are created by registrants to give information to downstream users about the identified uses of a substance and the potential risks they represent for human health and/or the environment. The information contained in these exposure scenarios is communicated down the supply chain in the annex of safety data sheets, either as such or in a consolidated form.
A collaborative partner in improving supply chain communication
A.I.S.E. has been a signatory of the Chemical Safety Report/Exposure Scenario (CSR/ES) Roadmap and a member of the Exchange Network on Exposure Scenarios (ENES), two important initiatives by ECHA and stakeholder organisations to improve the assessment and communication of the safe use of chemicals. Together with other DUCC members, A.I.S.E. has taken the lead on several action areas under these initiatives, such as the creation of comprehensive and generic information to assist in exposure assessment for substances used in our product portfolio, and the development of Use Maps for our product portfolio.
The tools created by A.I.S.E. were used in the DUCC/CEFIC pilot work in 2018-2019 on exposure scenarios and supply chain communication, which took place in collaboration with CEFIC and ECHA under the banner of the Exchange Network on Exposure Scenarios (ENES). This valuable cooperation between registrants and downstream users enabled discussion on points of improvement to strengthen the tools.