Site & Downstream Consequences

One important benefit of registration is that chemical suppliers and users can access a wealth of information on the properties of those substances, even if they themselves have not registered under REACH. This information should be used by companies to ensure their site practices are safe and compliant, as well as when preparing their own safety data sheets for customers. For the recipient, those new or updated SDS can have significant consequences to site working practices.

What’s more, change to classification under CLP means more substances than before may be regarded as hazardous, in turn coming into the scope of other European legislation on chemical use and supply as well as workplace and environmental management legislation.

Affected legislation

REACH is by no means the only EU law related to hazardous chemicals. There is a myriad of legislation - some Regulations, some Directives transposed into National laws - that come into play if and when a substance is classified as hazardous, having effects on the body or on the environment.

Furthermore, REACH applies without prejudice to other EU workplace and environmental legislation. The laws should be complementary, not compete. Downstream users not only need to comply with REACH but also with national and EU laws concerning worker protection, chemical storage, effluent release to the environment, pollution prevention and control, site planning… the list goes on!

The interaction between REACH and other laws is complex. We run training events specifically to help downstream users understand how SDS under REACH are changing and how it affects them. As a taster you will find some of the highlights below.

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Chemical Agents Directive

Directive 98/24/EC is concerned with the protection of the health and safety of workers from the risks related to chemicals at work. In the UK this Directive was implemented as COSHH.

Exposure limits are set by national workplace safety legislation based on the Chemical Agents Directive. For example, in the UK there are Workplace Exposure Limits, WELs, listed in the HSE’s EH40 publication. Such limits usually refer to inhalation and must not be exceeded.

REACH establishes Derived No-Effect Levels (DNELs), levels at which exposure causes no effect health. For industrial and professional applications there are DNELs for inhalation and also for dermal exposure. Workplace monitoring data may be useful in demonstrating the exposure of downstream users is below the DNEL, however such data must be reliable, representative and reproducible. In some instances downstream users may need to prepare their own Chemical Safety Report to demonstrate their uses are safe.

REACH and the Chemical Agents Directive should complement each other. One does not take precedence, and complying with one does not automatically mean a company is in compliance with the other.

For more information please see Uses and Exposure Scenarios.

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Major-accident hazards - the SEVESO Directive

Directive 96/82/EC (as amended) is aimed at the prevention and control of major accidents in the chemical industry at sites where dangerous substances are present in high volumes. In the UK this Directive is implemented as the COMAH Regulations.

With more information available on the properties of substances due to REACH, and changes to the way they are classified due to CLP, more substances may fall in scope of SEVESO - meaning more sites can be affected. Previously low-tier sites may also find themselves in higher tiers in light of these changes.

Do you know how the interaction between REACH, CLP and other legislation affects you? If not, come along to one of our training events.

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You can call our Helpdesk number on +44 (0) 20 7901 1444. Or e-mail us on enquiries@reachready.co.uk.