What are the options to communicate criticial information not in the - - PowerPoint PPT Presentation

Supply chain communication-

What are the options to communicate criticial information not in the SDS?

Randi Hanstveit, REACH Specialist, Sealed Air

Markets we serve

.

Health Care

INFECTION PREVENTION

Retail

OPERATIONAL EFFICIENCY

Distribution

INNOVATION

Food Service

FOOD SAFETY

Hospitality

SUSTAINABILITY

Building Service Contractors

LABOR PRODUCTIVITY

Building Care Infection Control Consumer Brands Food Safety Fabric Care

Key Categories of Cleaning products

The problem to be solved

The Supply Chain requirement of REACH: [31.7] […] Any downstream user [= formulator] shall include relevant exposure scenarios, and use other relevant information, from the safety data sheet supplied to him when compiling his own safety data sheet for identified uses. ECHA DU Guidance: The objective is to convey information that helps to protect human health and the environment in a way the recipient can easily understand.

What is relevant critical REACH information?

• Required exposure controls
• PPE, ventilation, organisational control, containment etc
• Assumed conditions of use or ‘ operational conditions’ (OC)
• Duration, frequency, max concentrations etc
• Substance data:
• Phys/chem characteristics that may be relevant for risk assessment
• DNELs, PNECs
• (Eco)toxicity data where available and relevant for safety

NOT 1 –to-1 copy from substance to mixture!!!

• Reactions
• Change of physical state (dilution)
• >1 supplier per substance,

AND: Different requirements for concentrated product/use solution Normally not in SDS

REACH Supply chain Communication [ECHA DU guidance] Ideal situation….

REACH Supply chain Communication [ECHA DU guidance] With new tools that are (being) developed at EU level to Improve communication in supply chain SWED AISE: Use Map SUMI

LCID

SPERC SCED

REACH communication in supply chain (Actual)

Manufacturer Distributor Downstream user Downstream user Distributor End - User Waste Distributor

Customer Distributor Formulator- Diversey Synthesis Sales Co Raw Material Trader

Identify Use

Send Safety Data Sheet

Use communication With ECHA’s Descriptor system! (SU, PROC, PC, ERC)

End-user REACH obligations

[Art 37]

• End users shall identify, apply and recommend appropriate measures to

adequately control the risk of the use of a product as given in SDS.

• Shall check in SDS if their use AND conditions of use are covered in SDS.
• If so=> OK.
• If not, the downstream user has to take action! not compliant

[Art 35] Workers shall have access to information (for example via worker instruction card)

• BUT: Occupational Health and Safety (OHS) legislation also applies!
• => Workplace risk assessment (RI&E in the Netherlands)

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Supply chain communication & formulator options in REACH:

• Formulators pass relevant information in substance extended

SDS (esds) along the supply chain to their customers.

• (REACH) Options for mixtures:
• 1. Integrate the information into the main body of the SDS (=

current SealedAir method)

• 2. Append safe use information for the mixture
• 3. Attach relevant exposure scenarios for the substances in the

mixture in an annex  Not possible

• 4. NEW INDUSTRY DEVELOPMENT: combination 1,2 : GEIS (NL)

 now ‘ SUMI’ (EU)

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Why was SUMI (fka GEIS) developed in the Netherlands?

• Conflict between REACH requirements and existing practice for complying

to occupational law and the ‘ Risk Inventory & Evaluation’ (RI&E)

• ‘Stoffenmanager*’ required by authorities/ advised by cleaning companies

trade organisation for Risk Inventory

• In the past only available option
• Not aligned with REACH
• Not appropriate for mixtures
• Too specific knowledge required for most small companies (SME)s
• Formulators could not deliver required information
• Enforecement organization in NL agreed that Stoffenmanager could be

replaced with REACH data

GEIS =Generic Exposure Information Sheet

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*Stoffenmanager= Dutch risk/exposure assessment tool

GEIS- project (NVZ)

• Goal: standardize and simplify the way of communicating safe use

information to end users in our industry sector.

• ‘ Appendix ‘ to the SDS of professional cleaning products (optional)
• Using standardized use processes: EU trade organisation (AISE)

contributing scenarios

• Easy to understand and use by cleaning companies (also small companies)
• Easy to implement for formulators

Source: Dutch industry trade body NVZ, the Netherlands, www.NVZ.nl

Principle of SUMI

Specific for cleaning sector (highly diluted use solutions) See: http://www.ducc.eu/Publications.aspx For SUMI format and guidance

THIS IS SUMI THIS IS NOT SUMI Industry-wide harmonised format. Does NOT replace worker instruction card Flexible: combination of activities possible Use-specific document (not product specific) Does NOT replace Safety Data Sheet

• SDS includes product-specific

information Formulator is doing the substance use compliance check for end user Complete Risk Assessment (including wet work, vulnerable worker, slip danger etc)

Combination of all AISE_SUMI

AISE SUMI.[PW/IS].[PROC#].[A(noPP E)/B(goggles)/C(gloves+goggl es)/D(LEV+gloves+goggles)][1 (480min)/2(240min)/3(60min)/4 (15min)].version#

AISE SUMI.PW.8a.C3.v1 Transfer of product to a container (bottle/bucket/machine) PW PROC8a 60 No No Yes Yes AISE SUMI.PW.8a.B3.v1 Transfer of product to a container (bottle/bucket/machine) PW PROC8a 60 No No Yes No AISE SUMI.PW.8a.A3.v1 Transfer of product to a container (bottle/bucket/machine) PW PROC8a 60 No No No No AISE SUMI.PW.1.A1.v1 Using a product in fully closed equipment PW PROC1 480 No No No No AISE SUMI.PW.4.A1.v1 Using a product in semi-closed equipment PW PROC4 480 No No No No AISE SUMI.PW.11.A3.v1 (Trigger) spraying of a product PW PROC11 60 No No No No AISE SUMI.PW.11.B3.v1 (Trigger) spraying of a product PW PROC11 60 No No Yes No

Eye protecti protecti

• n of

RMM Respira tory use descriptors Exposure Modifier

Duration per day

LEV? SUMI-Code Short description of process or activity Life Cycle Process Category

13published ‘ GEIS’  NEW: 18 SUMIs for professional use 21 SUMIs for industrial use

‘ Core data’ for SUMIs: Overview SUMI with OC/RMM

How to use SUMI as formulator Define relevant uses of mixture Check ESs of substances

• Only for substances contributing to classification
• Required activities and use conditions covered by

substance suppliers?* Select relevant SUMI per product and send output

• SUMI-code in Section 1.2 of SDS
• Optional: Append applicable SUMIs

Principle of SUMI continued

Big effort for formulator!

Source: NVZ *Base check on Use maps and ‘ SWEDs’ as published by EU trade organisation AISE

Note: Not classified? SUMI not needed.

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Example kitchen surface cleaner formulator’s task

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Recommended Activity: Cleaning in kitchen, trigger spray application 1) Select required Life cycle stage & PROC LCS & PROC SUMI in section 1.2

Dilution of product in bottle (transfer) PW PROC 8a AISE SUMI.PW.8a.C3.v1 trigger spraying PW PROC 11 AISE SUMI.PW.11.A3.v1 wipe PW PROC 10 AISE SUMI.PW.10.A1.v1 2) Ensure that these uses/conditions are covered by the raw material suppliers/registrants for all substances in product 3) Include SUMI codes in SDS (section 1.2). 4) Customer can find relevant SUMIs on AISE/NVZ website, or get the relevant copies

AISE SUMI example

DRAFT

AISE SUMI example

DRAFT

DRAFT

AISE SUMI example

Principle of SUMI for end user

How to use SUMI as end –user? SUMI intended for employer, not directly for worker Check section 1.2 of SDS for SUMI codes and relevant SUMIs

• Are your uses covered in SDS?
• Collect the relevant SUMIs
• Check SUMI and SDS. Do you have the correct safety controls in place?
• Prepare worker instruction

Use SUMI to prepare Worker Instruction Cards (or similar documents)

• Cleaning company association (OSB/RAS) developed tool with TNO
• Tool aligned with SUMIs
• See https://www.arboschoonmaak.nl/wik-maker/

• Dutch Cleaning company association working on tool to get from

SUMI to ‘Workplace Instruction Card’ (WIK in Dutch)

• See WIK maker (https://www.arboschoonmaak.nl/wik-maker/)
• Trade association members (Formulators) enthusiastic about

simple approach to comply with REACH

• Authorities openly supportive
• Dutch enforcement body: if compliant with SUMI conditions, no
• wn (chemical) risk assessment needed for mixture
• KEEP IN MIND: OTHER OPTIONS ARE ALLOWED AS WELL

SUMI acceptance in the Netherlands

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Task end user- What is changed due to SUMI in the Netherlands Old situation New Situation SUMI REACH data incorporated in SDS Risk assessment with Stoffenmanager Use check / check safety advice in SDS and SUMI Use check / check safety advice in SDS* Collect substance/product data from formulator for risk assessment (not possible) End user will get appropriate information from formulator Checks other safety aspects than chemistry (wet work, vulnerable workers etc) No change No change End user creates WIC End user creates WIC, but can use WIK-maker No change *Check how supplier communicates operational conditions and use descriptors

Transition to SUMI

Validation project ongoing -European Trade Organisation (AISE)

• Create sector use maps:

− reworking list of SUMIs/contributing scenarios into new format of ECHA.

• Create SWEDS, SPERCS, SCEDS (for communication with registrants)
• Validate SUMIs , professional (NVZ) and Industrial (IHO)

Timing: use maps: expected Q3 2016 SUMI publication: end 2016 Implementation by companies >2016! NOTE: Companies are not obliged to provide SUMIs! http://www.ducc.eu/Publications.aspx