Identified Uses and Exposure Scenarios

Under the REACH legislation, each chemical substance manufacturer or importer is required to register their substances at the appropriate date (Dec 2010, June 2013 or June 2018).

If the substance is hazardous (from the toxicology testing results) the registration dossier must include a risk assessment to man and the environment. This risk assessment needs to consider each identified (supported) downstream use of the substance, and its disposal as waste.

What is an Exposure Scenario?

Part of the risk assessment process includes the creation of an Exposure Scenario (ES) for each phase of the lifecycle of the substance. A separate ES will be required for each Identified Use, and for disposal. The ES defines how humans and the environment are exposed to the substance, and how that exposure is controlled by applying the appropriate Operational Conditions (i.e. how the substance is to be used) and Risk Management Measures (describing the precautions needed to handle the substance safely). Ultimately the Exposure Scenario will form part of the Extended Material Safety Data Sheet for the substance.

It should be noted that Exposure Scenarios apply only to substances. Where a preparation is supplied (eg a formulated lubricant), this preparation will have an ES associated with it, based on the properties of any hazardous component in the formulation.

How will Identified Uses be communicated?

The European Chemical Agency (ECHA) (http://echa.europa.eu/) in its Publications section has provided a document called Guidance on Information Requirements and Chemical Safety Assessments for the communication of substance Identified Uses according to a standardised “Use Descriptor System”. This is intended to harmonise communication up and down the supply chain and facilitate information exchange of Identified Uses.

The upward communication of uses in the supply chain is an essential step and needs to be completed at least 12 months before the respective registration deadline so that the substance registrant can include the Identified Uses in his registration dossier. Hence the first deadline is the end of November 2009 for substances to be registered in 2010.

If a downstream user (‘our customer’) of a substance or a formulation wishes their use to be considered in the substance registration dossier, then they need to check that their use will be covered by their supplier (i.e. Castrol).
To help in this process the European lubricants industry, through a dedicated Association working group, has reviewed several hundred lubricant products using the “Use Descriptor System” and condensed them to a smaller number of generic uses. Each downstream user is strongly recommended to review this list and assure themselves that their use(s) of specific lubricants are covered by the Descriptor System. The same system will then be used by the substance suppliers for preparation of the Exposure Scenarios and Extended MSDSs.

All the information relating to lubricant uses has been placed under the REACH tab on the following website:

www.atiel.org

Before accessing this site to check that your uses are covered, please download and read the attached file, which provides a simplified guide to understanding the Use Descriptor System for the lubricant products purchased by downstream users.

Simplified Guidance to Identified Use Communication , pdf , 137KB

Further, more comprehensive, background and instructions are on the ATIEL website.