ETUC Conference on REACH March 2005 Improving REACH ETUC proposals for Downstream Users and SMEs Bernd EISENBACH EFBWW

ETUC Conference on REACH March 2005  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 activities e.g.: building trade, woodworking industry, textiles, agriculture…  Most of the Downstream Users are SMEs  Downstream Users = several millions workers in EU-25 Downstream User

ETUC Conference on REACH March 2005 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 March 2005  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 March 2005 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 March 2005 EFBWW fully supports the ETUC positions on REACH.