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COMMUNICATION ALONG THE SUPPLY CHAIN

how downstream users can/should play their role?

Sylvie Lemoine (A.I.S.E. / DUCC)

18 April 2012

REACHCentrum conference, Brussels

DUCC = platform for associations whose member companies use chemicals to formulate mixtures as

finished products for end users (consumers and professional users)

DUCC focuses on DU needs, rights, duties and specifities under REACH and CLP

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Presentation outline

• Supply Chain Communication (SCC): setting the scene – Main requirements - reminder

– Main issues – DU level

• Emerging solutions – Use communication M/I – DU

– SPERCs

– Learnings from 2010 – preparing 2013

- Implement RMM - Communicate SDS (ES) to his own DUs

Communication in the supply chain

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DU’s own Chemical Safety Report (only if used > 1t/y)

or

M/I Annex:ES

SDS SDS (with ES) + other information

- Use and exposure information - Check RMM / ES : report if needed - Report new information

Annex:ES?

SDS

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SCC Issues

• Supply chain communication goes multi-level, multi-player

• Supply chains are complex

• Flow of communication: need balance between top-down and bottom-up are needed

• Existing mechanisms are not obsolete, but they are not sufficient – Safety Data Sheets – Letters – Contracts – E-mails

• Improvement areas: structuring and harmonising ! – Tools to use (including standard phrases) – Formats and content

Preparing 2013

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• DU’s right to make uses known in writing (Art 37(2))

– 12 mths before registration deadline must be considered by registrant

– Provide ‘sufficient information’

– Upstream supplier, if not the registrant (e.g. DU, distributor), must forward upstream

• Top-down approach is preferred in practice

• Letter (for M/I) and fact sheet on use communication posted on Cefic’s (and others’) websites

http://www.cefic.org/Industry-support/Implementing-reach/Guidances-and-Tools1/

Use communication: Prior to registration

Based on the 2010 experience, Industry has agreed to follow the top-down approach for use communication:

No need for DU to pro-actively communicate common uses up the supply chain

(e.g. those covered in the existing SDS, those already registered, those included in sector associations)

Industry agreement on use communication for 2013 registrations DUCC, Cefic, Fecc and Concawe

Manufacturers/Importers to inform DU on the uses they intend to cover (e.g. via a link, website, reference to some use mapping from sector associations,…)

Downstream users to check the available sources of information on uses

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Industry agreement on use communication for 2013 registrations DUCC, Cefic, Fecc and Concawe

When should the DU communicate his use(s)?

If DU has a particular use as soon as possible

If DU use(s) is missing in the communication received as soon as possible

If DU does not receive any communication May 2012 (?)

Art 37(2) DU’s right to make uses known

12 mths before registration deadline

How?

DU should provide sufficient information: use descriptors + OC/RMM (as a minimum)

DU should communicate in a substance + supplier specific way

DO’s and DON’Ts for USE REPORTING

DO’s

Before reporting Check current SDS – Section 1 (uses, indication of later registration or exemption)

Check supplier’s website

When reporting (if needed)

Contact supplier via indicated means (standard form, link, email, …)

Substance + Supplier specific reporting (e.g. only uses applicable to a given mixture)

Use standard formats: DUCC UseR template + Use Descriptors (R.12 ECHA Guidance)

Provide info on OC + RMM (as a minimum)

DON’Ts

When reporting Send tables with all possible combinations of uses/UD

Change the use descriptors prepared by Associations

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• Developed by DUCC for mapping and reporting uses

• Used by DUCC members to develop use mapping tables on behalf of their sector

• To assist DU in informing their suppliers on their uses and conditions of use

• In line with Cefic SES template

• Builds on the Use Descriptor System

• The information (use descriptors, OC/RMM) provided allows 1. Description of activities/uses of DU in a sector

2. Exposure assessment at Tier-1 level based on ECETOC TRA (Targeted Risk Assessment) Tool

• Each DU Association fills in the tables for its own sector, acting as a surrogate for individual companies (but not on behalf of companies)

UseR Template ... a simple and valuable tool!

TIP

UseR is also helpful for DU to check use coverage when receiving ext-SDS/ES

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DUCC UseR: Description of uses

(excerpt – for illustration purposes)

1

Blending/dissolving/dispersion:

mixing, dispersing, grinding -

closed continuous process (no

sampling)

SU 10 PROC 1 N.A. N.A. N.A. ERC 2

2

Receipt and storage of raw

materials: bulk raw material

delivery (e.g. pigments/extenders)

– outdoor

SU 10 PROC 8b N.A. N.A. N.A. ERC 2

3

Air Fresheners aerosol

(aqueous, non-aqueous,

concentrated) for consumer use

SU 21 N.A. PC 3Aircare, instant action

(aerosol sprays)N.A. ERC 8a

4

Air Fresheners (timed-release

aerosols, perfum in/on solid

substrate (gel), candles, diffusers

heated and electrical)

SU 21 N.A. PC 3Aircare, continuous

action (solid & liquid)N.A. ERC 8a

PROC 2 N.A. N.A. N.A.

PROC 8b N.A. N.A. N.A.SU 3 ERC 4

Industrial

manufacture of

coatings and inks

(PC5, 9, 18)

Consumer Use of

aircare products

CEPE

1.1

5FEICA

I.2

Automated

application of water-

borne adhesive -

Industrial

T.B.D.

USE DESCRIPTORS

Sector of

use (SU)

Process

Category

(PROC)

Product

category (PC)Product Sub-category

Article

Category

(AC)

Environmental

Release Category

(ERC)

Number

(for DU)

Code

(for DU)Short ES title

Short description of process or

activity

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DUCC UseR Basic exposure information for ECETOC-TRA assessment

...

… New version available at:

http://www.duccplatform.org/activities/use_and_exposure_info.html

UseR – update in February 2012 ...to help in having more realistic ES!

New column Operational conditions: "concentration of substance in the mixture (w/w)". This is an optional parameter, which is substance specific, to be filled by each company, if considered relevant. The concentration should be indicated according to the exposure modifier of ECETOC TRA, i.e. by means of one of the following ranges: <1%, 1-5%, 5-25% or >25%.

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• (Extended-)SDS – Section 1

– Exposure scenarios

• M/I: – Table of content at beginning of SDS annex, with list of ES

– Consistency with use mappings

• DU: – Assess options in case of missing use

– Further communicate downstream

– Check consistency with use mappings

Use communication : Post- registration

• Follow the Use Descriptor System

• Follow templates and models

e.g. DUCC UseR template (for use mapping) and

Cefic guidance

• Follow ECHA guidance (ES headings/format)

• Increase training/awareness of all actors

Use communication : In general

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• First level Environment Assessment under REACH based on ERC’s (R16)

• Release defaults set for ERC based emission estimates are worst case assumptions

• This may lead to overly conservative results

• An approach applying more realistic values (lower-tier assessment) while keeping standardisation appears reasonable

SPERCs: Why? Specific Environmental Release Categories

• More than 170 SPERCs available

• SPERCs are an element of standardised supply chain communication of environmental assessments, e.g. in GES

• SPERCs have been extensively used for generating the dossiers of the 2010 REACH registrations

• SPERCs format and documentation are currently being reviewed for inclusion into CHESAR

• All published on the Cefic web site + available on DU association websites

SPERCs: What? Specific Environmental Release Categories

• Refinements of the ERC-based emission estimation

– define realistic default values (based on good practice information supplied by DU sector groups, trade associations).

– are documented in SPERC fact sheets

– Are included in ECETOC TRA v3 (environment)

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SPERCs: example And now… the SCEDs Specific Consumer Exposure Determinants

• SCEDs = SPERC-analogs for consumer assessment

• Refinements of exposure assessment for consumers based on ECETOC TRA consumers i.e. avoid having to run ConsExpo

• Refine default parameters of TRA consumers e.g. frequency of use, habits and practices of consumers

• DUCC coordinated project initiated – A.I.S.E., CEPE, FEICA, FEA

• SCEDs to be made available for 2013 registrations

– Templates to be populated and made available by July 2012

• Longer-term: include in Chesar

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Longer-term horizon

The ESCOM package Exposure Scenario COMmunication

• ESCom: standard phrases + IT standard (XML) for ES Communication between companies IT systems in the supply chain

• The ESCom package products

ESCom XML 1.1 – The Container for ES Info

XML Schema-definition

ESCom XML guidance document

Technical documentation

Example of an XML-File

ESCom Standard-Phrases - The Content for ES Info

Master-File with standard-phrases for ES (incl. phrase-codes)

> 1900 phrases

Guidance document for phrase development

> 1000 downloads since May 2011

http://www.cefic.org/Industry-support/Implementing-reach/IT-Tools/

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• ESCom should be applicable for the downstream communication of ES over the whole supply chain

• Made available for free (English only)

• Aligned with BDI EuPhraC phrase system for SDS

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2. The ESCOM package objectives

Will only work if all players in the supply chain apply XML and phrase standards IT providers to develop interface to implement it into their SDS softwares

Should be used for the entire ES, no/limited for free text

Will take some time to implement in the supply chain and to have

all IT systems upgraded

M/I Exposure

Assessment Tool

DU Scaling

Tool

Formulator Mixture

Assessment Tool

GES

SpERC

EsCom Phrases

Data

Std

ESCom

XML

ESCom

XML

ESCom

XML Industry

standards

Chesar

TRA

?

Tools for

Mixture

Assessment

Under

Development

Scaling

Tools

Under

Development

2. The ESCOM package Industry’s vision

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2. ESCOM: next steps

• ESCom 2 being set up (2012-2014): Cefic / DUCC / IT providers

• Alignment/compatilibility with Chesar 2.0 (ECHA) stable XML standard

• Maintenance and update, focus on standard phrases – Standard phrase maintenance

– Procedures and tools to manage / download

• We are still in a learning phase, but we need to build on 2010 learnings

• Good supply chain communication and discipline will help in generating realistic exposure scenarios

• Standardisation via IT tools and harmonised templates / formats: use ES format of ECHA guidance

• Build on existing tools, guidance and emerging solutions – Further improvement of assessment tools

• Need to optimise communication flows (top/down vs bottom/up)

• Training of all players is needed

Conclusion: we need standard and pragmatic solutions