REACH requires downstream users, such as formulators, to provide their customers with information on the safe use of mixtures. The downstream users determine how to present the material – in a safety data sheet or in an annex – and how to transmit the required information. And because the information can be comprehensive, the effort involved in collating it can be significant. Accordingly, companies that need to provide the information look for the simplest possible solutions.
Two approaches are under development right now. The first is the bottom-up approach, in which companies use existing information on the safe use of mixtures. The information is gathered for mixtures typically used in an industry sector and put into a uniform structure. This approach produces generic information sheets: Safe Use of Mixture Information (SUMI).
The Downstream Users of Chemicals Co-Ordination Group (DUCC Group), an association made up of various industry sectors (laundry and cleaning materials, dyes, construction chemicals, and so on) has created guidelines for downstream users according to the bottom-up approach. The authors of the guidelines describe how users can collate the information required by REACH and transmit it to their customers without a great deal of effort.
The second approach is called top-down: Companies derive the relevant information from the exposure scenarios of the materials contained in the mixtures. The leading method for this approach is the Lead Component Identification Methodology (LCIM) – see the blog entry for October 29, 2015.
Each of the two approaches has its advantages. The preferred approach depends on the customer of a downstream user. If the customer is an end user, such as a cleaning company, for example, the bottom-up approach offers significant advantages.
KFT prepares safety data sheets for both approaches. In this context, we would like to mention our seminars:
February 18, 2016 „Das erweitere Sicherheitsdatenblatt (eSDB) für Gemische” and February 25, 2016 „Auffrischung und Vertiefung Fachkunde/Sachkunde zur Erstellung von Sicherheitsdatenblättern” (both only in German). If you have any questions, please contact us under firstname.lastname@example.org.