Uses and Exposure Scenarios

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One of the fundamental aims of REACH is to improve protection of human health and the environment from the risks of chemicals. To do so, REACH requires information on how and where those substances are used, who may be exposed to them, and how the substance may reach the environment. Together with the intrinsic properties of the substance, this information is used by industry to carry out a Chemical Safety Assessment. Once this risk assessment has been carried out, suppliers communicate advice on safe use to their customers through the extended Safety Data Sheet which details the Exposure Scenario.

Mapping uses

For most substances, there could be hundreds of individual uses in a supply chain. To make the task of collating information more manageable, experience shows that a top-down approach usually works best: the registrant identifies the uses they intend to register and communicates this information to customers (the users), who can then feed back that they have other uses.

The best approach usually makes use of standardised mapping templates based on ECHA’s Use Descriptor Codes, commonly known as Chapter R.12.

Downstream User rights

REACH gives Downstream Users the option to make known their uses to their supplier so that they can be included as a registered use.

Downstream Users may wish to keep a use confidential. In this case they may need to inform ECHA of their use; they may also need to prepare their own Chemical Safety Report.

Uses not covered by a registration

If a use is assessed and suitable risk management measures cannot be devised, the registrant should list it is a “use advised against” in the dossier and inform ECHA and the Downstream User.

Registrants may also consider it uneconomical develop an exposure scenario for a particular use. In this case they should not supply the substance for that use.

Exposure Scenarios

The supply chain will see the outcome of all this work in the form of the extended Safety Data Sheet. “Extended” means that Exposure Scenarios are annexed to the SDS. Such Exposure Scenarios are summaries of the risk assessment of the uses included in the registration dossier. They should complement and provide additional information to the SDS on the risks associated with the particular use and how to manage them.

Exposure Scenarios do not replace workplace or environmental safety assessments; receiving extended or otherwise updated SDS can have important consequences on site practices - see our webpage for more information.

Receiving extended SDS triggers a workflow of obligations for Downstream Users. They must first assess whether their uses are included within the supplier’s Exposure Scenarios. Where their use is not included in the registration or their site practices - for example the Operational Conditions (OC) or Risk Management Measures (RMM) - differ they will need to assess it the use is still in the scope of that Exposure Scenario. You might have heard about “scaling”, a method used to help Downstream Users demonstrate if their practice is covered.

If it turns out a use is not covered the Downstream User may need to notify ECHA, and they might need to prepare their own Chemical Safety Report.

Some of these activities must be completed within 6 months of receiving a registration number in the SDS, others within 12. We run training courses specifically for Downstream Users on how to deal with Exposure Scenarios. Why not come along to the next one to find out more?

You can call our Helpdesk number on +44 (0) 20 7901 1444. Or e-mail us on enquiries@reachready.co.uk.