AIHce Indianapolis



RT 219
Downstream User Obligations Under REACH

Tuesday | 1:30 p.m.–5:30 p.m. |

Stewardship and Sustainability

Arranger: R. Skoglund, 3M Company, St. Paul, MN. Moderator: P. Harper, ENVIRON, Phoenix, AZ. Monitors: K. Thompson, F. May, 3M Company, St. Paul, MN.

REACH (Registration, Evaluation, Authorization and restriction of CHemical substances), the European Union’s regulation on chemicals and their safe use, has significantly raised the prescriptive nature of the risk management responsibilities of downstream users of chemicals in the European Union.  Under REACH, a downstream user of REACH-registered substances is responsible for ensuring that their uses and the risk management strategies they implement are within the boundaries of what the manufacturer or importer of the substance has registered.  In addition, the downstream user is obligated to ensure that the relevant aspects of the risk management strategy are communicated down the supply chain as part of the REACH extended Safety Data Sheet (eSDS).  Compliance with this regulation presents a unique situation to the practicing industrial hygienist wherein there is a statutory obligation to implement a risk management strategy that fits within the boundaries of the strategy delineated by the registrant.  In addition to fitting a risk management strategy within the boundaries of the registration, downstream users must also reconcile registered and intended uses; foster for the co-existence of REACH exposure and release limits with traditional limits; and manage the potentially redundant, incompatible, or even contradictory risk management strategies of multiple registered substances within a process or mixture.

  • Overview of Downstream User Obligations Under REACH. P. Harper, ENVIRON, Phoenix, AZ.
  • Downstream User Chemical Safety Assessment. M. Van Tongeren, Institute of Occupational Medicine, Edinburgh, United Kingdom.
  • Systematic Description of Registered and Intended Uses under REACH. L. Dell, ENVIRON, Amherst, MA.
  • Coexistence of REACH DNELs and DMELs and Traditional Exposure Limits (OELs). R. Roy, 3M Company, St. Paul, MN.
  • Reconciling Registered and Intended Risk Management Strategies. R. Skoglund, 3M Company, St. Paul, MN.
  • Communicating Risk Management Strategies Down the Supply Chain. D. Deeds, Industrial Health & Safety Consultants, Huntington, CT.
  • Managing Mixtures Within a REACH Compliant Risk Management Strategy. P. Logan, 3M Company, St. Paul, MN.
  • Workshop and Audience Participation. P. Logan, 3M Company, St. Paul, MN.