Helping customers Tony Newbould BCF Consultant Eastwood Hall
Helping customers Tony Newbould, BCF Consultant Eastwood Hall, Nottingham Wednesday 30 March 2011 1
What they may request 2
Downstream myths “I want registration numbers for all substances now” “I want an ES for all coatings/inks now” “I want ESs for all substances now” “ No SVHCs in the products you supply” “Tell me what newly added Candidate List substances are in your products” • “Tell me how to interpret the ES you’ve sent me” • “Give me simpler/easier understood information” • “Tell me what controls I need to put in place” • • • 3
DU ES responsibilities • legally: only to forward to next step in use chain information, as received, relevant to that, and rest of chain ― industrial/professional user: part of the SDS ― consumer: primarily product label 4
DU ES responsibilities • legally: only to forward to next step in use chain information, as received, relevant to that, and rest of chain ― industrial/professional user: part of the SDS ― consumer: primarily product label Reminder: - DU only required to be reactive on info from upstream - wait for it to come to you - no need to go and seek (and same applies to your customers!) - your and customer’s processes are REACH compliant 5
Your options • do only what is required – are in legal compliance potential business relationship issues • take on user responsibilities – satisfy business relationship – satisfy Product Stewardship obligations liability implications 6
Liability aspects • REACH requires you only to forward relevant information received from upstream • do just this - then are legally compliant • do anything more than this then, potentially liable if a human health or environmental effect as a result of a DU adopting “your” ES instructions – – – you edit received ES content you put your name on an M/I’s ES you produce an ES for a mixture you interpret an ES for a customer you advise a customer on ES control measures 7
Decisions? • recognised difficult choice • what you do will depend on your confidence with situation • legislators, member states, regulators, industry all on a learning curve • better for someone else to be the path-finder? • penalty for not providing information likely to be lower than consequences for overdoing it 8
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