Central to the ongoing regulation and innovation of chemical usage in European production and manufacturing is the European Chemicals Agency (ECHA), which is responsible for implementing the European Union’s groundbreaking chemicals legislation for the benefit of human health and the environment.
REACH regulations are the primary means by which the ECHA works to ensure the protection of human health and the environment from the risks posed by chemicals. A critical and innovative component of these regulations are exposure scenarios, which is a document of chemical safety prepared for all substances that are manufactured in or imported into the EU in quantities of 10 tonnes or more and are considered to be hazardous, including all PBT and vPvB substances.
What is an “exposure scenario”?
An “exposure scenario” documents the ways a substance is manufactured or used at each point in its life cycle, through its final disposal as waste, and specifies the control methods recommended by the manufacturer or importer to help reduce or avoid exposure to people and the environment. Each exposure scenario must include risk assessment measures and operational conditions that ensure all risks associated with the use of the substances can be controlled appropriately. These include chemical storage guidelines and information on chemical storage safety.
Exposure scenarios are an essential element of safe chemical storage and handling, and contain important information for all downstream users of hazardous substances. However, they’re often included in the annex of a material’s safety data sheet (SDS) and can be easily overlooked. To encourage consideration of exposure scenarios, the ECHA gives guidance on what to do when you receive an ES.
How can I make best use of exposure scenarios?
Determine whether your use of a chemical substance is covered by the exposure scenario
For formulator or re-fillers, it’s important to consider the foreseeable uses of downstream customers. To do this, you’ll need to gather details on the actual uses of a material throughout your organisation. In which mixtures or items is the substance used? Which production, cleaning or maintenance processes use the material? Are any risk-management measures applied to its use?
Assess any differences between your conditions of use and those outlined in the exposure scenarios
It’s important to determine if your use case is covered in the exposure scenario, if your conditions differ slightly from the ES or if your operations are not covered. If your end products pass the chemical downstream to other users, it’s important to evaluate the downstream use and operations to see if they are covered by the ES. If you have any difficulty determining if your use conditions are covered, contact your supplier for additional information or guidance.
Documents your evaluation of processes
If your operations and conditions are covered by the exposure scenario, simply document your evaluation of your processes according to the ES and make the information available to enforcement authorities upon request. If your use conditions are not covered by the exposure scenario, you may ask your supplier to include your use in their chemical safety report and provide you with an ES for it.
Alternatively, you could modify your use and conditions to fit with the exposure scenario, eliminate or substitute the material, find another supplier with an exposure scenario that covers your use case or conduct your own chemical safety assessment and prepare a downstream user chemical safety report that covers your use, unless exemptions apply. Be sure to document any evaluation and decision, and make the information available to authorities should it be requested.
Careful consideration of exposure scenarios is an important step in ensuring safe chemical storage and handling. For additional advice or assistance with evaluating your chemical storage according to exposure scenarios, contact the expert team at Safety Storage Systems U.K.
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