REACH calls for action

The impact of REACH and its expectation of action from the converting industry are explained by Dr Hermann Onusseit, technical director at Henkel, of Germany.

REACH calls for actionConverting packaging materials demands the use of polymers, adhesives, printing inks and many other substances that contain chemicals. To achieve a high level of protection of human health and environment from the risk of using existing substances, in 2006 the European Commission issued new European chemicals legislation called REACH (Registration, Evaluation, Authorisation and restriction of CHemicals).

REACH is based on the idea that industry itself is best placed to ensure that the chemicals used in the EU do not adversely affect human health or the environment. This requires that industry has certain knowledge of the properties of its substances and manages potential risks.

REACH applies equally to the manufacturer, importer and downstream user, and, for all, the regulation has far reaching effects. Downstream users (DU) of industrial chemical products, such as the converter, are impacted if they produce, import or use substances in quantities exceeding one tonne per year per legal entity.

For registration purposes, both the properties and the use of the chemicals play a role. So it is important that the suppliers of chemicals know their customers’ applications, and any DU must be sure that its specific uses are registered.

Exposure scenario

Under REACH, each manufacturer and importer of substances must develop and assess exposure scenarios for its own markets, to ensure the safe use of every substance. It would be efficient to use a suite of generic exposure scenarios for the different markets and products, which can be modified case by case if necessary. In doing so, it should be possible to link the internal information related to products, markets and customers to exposure and product safety information.

For the DU, it would be efficient to receive standardised exposure scenarios for the relevant applications of the substances in their sectors, rather than a range of scenarios from different suppliers.

Short titles will help the suppliers and customers to structure their communication with each other. Based on the short titles, the DU should be able to establish quickly whether a received exposure scenario will cover their uses.

The use descriptor system

It is assumed that manufacturers/importers of chemicals know most of the uses of their substances and preparations. The supplier will be interested to receive information on all uses from his customers in a standardised way. A use descriptor system developed by the European Chemicals Agency (ECHA) identifies the suitable exposure estimation entry into one of the exposure estimation tools provided.

The use description is based on four elements:

¦ sector of use

¦ chemical product category

¦ process category

¦ article category

Downstream users

DU converters must ensure that their use of chemicals, including process chemicals such as oils and lubricants, is in compliance with the use registered by the manufacturer or importer.

Producers and importers of chemicals or preparations must make sure the customers’ uses are covered by the registration dossier. They must forward information on ‘identified use’ and ‘risk management measures’ down the supply chain and inform consumers how to safely use the preparations in ‘exposure scenarios’.

During the registration process, converters must check that their uses are covered in the registration dossier for all substances they use. ‘Use’ means ‘any processing, formulation, consumption, storage, keeping, treatment, filling into containers, transfer from one container to another, mixing, production of an article or any other utilisation’.

Industrial users of the packaging must apply risk management measures in their own production, if necessary, and check compliance with the exposure scenarios.

DU converters are required to consider the safe use of substances based primarily on information from their suppliers, and must apply appropriate risk management measures. DU will need to communicate effectively with their suppliers to get the information they need incorporated into a safety data sheet (SDS). In particular they must check their uses are covered by the SDS, and they use a substance only within the conditions described in the exposure scenarios in the annex to the SDS.

Especially important is the communication of substances posing human or environmental hazards and included in the ‘candidate list’ for Substances of Very High Concern (SVHCs) of ECHA. If a preparation or an article such as packaging contains more than 0.1% of such a substance, the whole supply chain must be informed.

To sum up, REACH expects converters to confirm their future intention to use specific chemicals. Along with its high aims, REACH will bring a lot of extra work, communicating with suppliers and customers and in compliance checking of substances.

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