Improving REACH ETUC proposals for Downstream Users and SMEs

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Improving REACHETUC proposals for Downstream
Users and SMEs

• Bernd EISENBACH EFBWW

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Downstream User

• Downstream User any natural or legal person
  established within the Community, other than the
  manufacturer or the importer, who uses a
  substance, either on its own or in a
  preparation, in the course of his industrial or
  professional activities e.g. building trade,
  woodworking industry, textiles,
  agriculture
• Most of the Downstream Users are SMEs
• Downstream Users several millions workers in
  EU-25

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Obligations of DUs under REACH?

• Consider the safety of their uses of substances,
  based on the information from their suppliers,
  and apply appropriate risk management measures
  (questions of guarantee !).
• How?
• Check that their use(s) are covered by the Safety
  Data Sheet accompanying the substance supplied to
  them, i.e. that they use a substance within the
  conditions described in the exposure scenarios
  in the SDS.
• SDS are prepared only for dangerous substances,
  under REACH SDS will be complemented by relevant
  information about risk control for all identified
  uses.

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• If substance is used within the conditions
  described in SDS, DU applies risk management
  measures communicated to him.
• If substance is used outside the conditions
  described in SDS, DU benefits from 2 choices
• inform the supplier of this use to make it an
  identified use, the supplier updates the SDS
  with appropriate exposure scenarios (through CSR)
• keep is intended use confidential and carry out a
  CSR himself ( DU Chemical Safety Report)

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ETUC proposals

• Inform DUs about their real obligations under
  REACH
• COM and MS to organise targeted communication to
  DUs
• REACH info/help desk in each country
• Help DUs complying with their duties under
  REACH
• Workable Technical guidelines for DUs and SMEs
  (RIP projects)
• National industry association or European
  federation to assist their members
• Sharing of the costs between producers and users
• COM to clarify impact of REACH on employment in
  the different DU sectors

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• EFBWW fully supports the ETUCpositions on REACH.