29.04.21

REACH – Obligations for downstream users

  • Review of the safety data sheet; identification and implementation of appropriate measures set out in the safety data sheet and the associated exposure scenario.
  • Information for suppliers (chemical suppliers) where new information regarding hazards or risks becomes available, or where the company’s own use of the substance is not listed in the safety data sheet.
  • When using SVHCs (substances of very high concern): Compliance with the requirements for substances of very high concern that have been included on the Candidate List (e.g. chromium VI, lead)

    – Check usage

    – Provision of information to the customer in accordance with Article 33 if the articles contain a substance of very high concern (SVHC) in a concentration exceeding 0.1 per cent by mass, and entry into the SCIP database for articles and products.

  • Use of SVHCs (substances of very high concern, which have been included in Annex XIV (e.g. chromium VI))

    – Use only with authorisation (e.g. from a supplier or consortium)

    – Checking whether your own use is covered by the authorisation

    – Registration of use with ECHA (REACH-IT account)

    – Where applicable, notify ECHA of your own use if this is not covered by an authorisation

    – Reviewing the safety data sheet to ensure it is appropriate for the company’s own use (conditions of use in the exposure scenario)

    – If the use is not covered, then a chemical safety report must be drawn up

    – Workplace exposure measurements and measurements in exhaust air and waste water (to be carried out by 18 June 2021, to be reported to ECHA by 31 December 2021) –> annually!!

    – Evaluation and documentation, as well as reporting the measurement results to ECHA by 31 December 2021 –> annually!!

    – Extension of authorisation or participation in a consortium

Your points of contact for further information:

Ulrich Mäule (+49 7171 104080. maeule@qubus.de)
Frank Schüle (+49 7171 1040817. schuele@qubus.de)

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