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Improving REACH ETUC proposals for Downstream Users and SMEs

Improving REACH ETUC proposals for Downstream Users and SMEs. Bernd E ISENBACH EFBWW. Downstream User.

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Improving REACH ETUC proposals for Downstream Users and SMEs

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  1. Improving REACHETUC proposals for Downstream Users and SMEs Bernd EISENBACHEFBWW ETUC Conference on REACH - 11-12 March 2005

  2. 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 activitiese.g.: building trade, woodworking industry, textiles, agriculture… • Most of the Downstream Users are SMEs • Downstream Users = several millions workers in EU-25 ETUC Conference on REACH - 11-12 March 2005

  3. 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. ETUC Conference on REACH - 11-12 March 2005

  4. 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) ETUC Conference on REACH - 11-12 March 2005

  5. 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 ETUC Conference on REACH - 11-12 March 2005

  6. EFBWW fully supports the ETUCpositions on REACH. ETUC Conference on REACH - 11-12 March 2005

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