WORKSHOP on EXPOSURE SCENARIOS “Communication in the Supply Chain” Helle Simon Elbro Danish Paint Association in collaboration with DHI SDS
WORKSHOP on EXPOSURE SCENARIOS Communication in the Supply Chain Helle Simon Elbro Danish Paint Association in collaboration with DHI SDS.
Mar 26, 2015
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WORKSHOP on EXPOSURE SCENARIOS
“Communication in the Supply Chain”
Helle Simon ElbroDanish Paint Association in collaboration with DHI
SDS
Agenda
• Danish REACH project
• Exposure Scenarios and our assumptions
• An example of “Description of Use”
• Further work
GOAL for Danish REACH projectProtecting/improving business
DU company
Raw materialsuppliers
Customers
ProducingProducts
Selling products
Sourcingraw materials
Pro-active
Tools
DU company
Raw materialsuppliers
Customers
Building Awareness
Tools
DU company
Raw materialsuppliers
Customers
Analysis of Product/raw materialAssortment(REACH TemperatureMeasurement)
Tools
DU company
Raw materialsuppliers
Customers
Extended RawMaterial Description
Tools
DU company
Raw materialsuppliers
Customers
Description of Use
Agenda
• Danish REACH project
• Exposure Scenarios and our assumptions
• An example of “Description of Use”
• Further work
CustomerSDS
Raw materialSubstance
SDS SDS
Product
Paint & Adh.
USE
EU Agency
Manufacturer
REACH Exposure Scenarios
Registration dossier
CSR
Extract EXPOSURE SCENARIO
Conditions of safe use 1) manufacture 2) usein entire life-cycle.
RMM’s 1) Human exposure2) Environment
incl. waste-handling
ES
Revision of ES(by M/I)
Identifieduse
Manufacturer
Paint & Adh.
SDSExtract
SDS
CSRrevised
SDS
Identifieduse
SDSX XManufacturer
Paint & Adh.
Break down orConfidential use
Development of ES by DU
CSRDU
EU Agency
NOTIFICATION
SDSExtract
Where will the ES be made?
M/I
DU
IncreasingComplexity
Better protection of Confidential Information
More valuefor whole industry
Sector - orNational level
Pro-activecommunication
Assumption 1: In general: ES’s should be made as high up in the supply chain as possible, but DU’s are to participate pro-actively - either on sector or national level.(In a few cases DU makes ES’s themselves)
Why is it so important to be pro-active?
Time
Few days
Years
Change of solvent based onCertificate of Analysis
New additive in functional product(wood-stain)
Lab-testing
Field evaluation
External documentation
Approval at Authorities
Validation at (industrial) customer
Paint & Adh.
What forms will the ES take?
Description of Use/Template Exposure Scenario
Inherent propertiesof chemical
+Final Exposure Scenarios
=
ManufacturerSDS
Substance
Assumption 2: DU’s makes description of use/Template Exposure Scenariofrom which the M/I’s make the final ES to be included in the SDS
Which part of the life-cycle to start from?
Paint & Adh.
or
Customer
Customer use
Assumption 3: In our work, we have started by describing our customers use:- Other actors up the supply chain have similar unit operations- Customers use is less controlled (limited industrial use)- Focus on use of formulated product.
Manufacture (own use)
Categories of chemicals Which should we have in mind - up front?
Assumption 4: Uses of all classified substances above a given conc. will need to be identified. - Substances with low classification/conc. may only need confirmation of RMM.- Other substances with higher classification/conc may need “more” precise description of use.
Raw materials
Increasing classification
Cobolt siccative (alkyd paints)
Additives (water-based paints)
Water
Butanone oxime (alkyd paints)
Determinants of exposure
HOW
RISK MANAGEMENT MEASURES
AMOUNT
FREQUENCY
DURATION
WASTE HANDLING STP
WHEREindoor outdoor
WHO
Paint & Adh.
Description of use -also includes RMM’s and Waste handling!
Final Exposure Scenarios
Inherent propertiesof chemical
+=
Manufacturer
FinalRMM’s and Waste-handling
Current (best) practice:RMM’s and Waste-handlingx or confirmed
Description of Use/Template Exposure Scenario
Agenda
• Danish REACH project
• Exposure Scenarios and our assumptions
• An example of “Description of Use”
• Further work
Scheme for Description of use
HOW
RISK MANAGEMENT MEASURES
AMOUNT
FREQUENCY
DURATION
WHO
WHERE
WASTE HANDLING
1. User: Who is using the end product? - Consumer - Professional - Industrial and how open is the system? - Closed - Semi-closed - Open
HOW
RISK MANAGEMENT MEASURES
AMOUNT
FREQUENCY
DURATION
WHO
WHERE
WASTE HANDLING
2. Application site: Where is the end product used? - Out-door - In-door
Scheme for Description of use
HOW
RISK MANAGMENT MEASURES
AMOUNT
FREQUENCY
DURATION
WHO
WHERE
WASTE HANDLING
3. Application type: How is the end product used? - Application by piston (e.g. for sealants) - Brushing/rolling - Stopping knife - Fluting - Flow coat - Spraying - Other
Scheme for Description of use
HOW
RISK MANAGEMENT MEASURES
AMOUNT
FREQUENCY
DURATION
WHO
WHERE
WASTE HANDLING
4. Amount of product used 1 kg 5 kg 10 kg 50 kg > 50 kg 5. Concentration of raw material in end product < 0.1 % < 1 % < 5% < 25 % < 50% 100 %
Scheme for Description of use
HOW
RISK MANAGEMENT MEASURES
AMOUNT
FREQUENCY
DURATION
WHO
WHERE
WASTE HANDLING
6. Frequency of use 1x /year 1x /month 1x /week 1x /day >1x /day
Scheme for Description of use
HOW
RISK MANAGEMENT MEASURES
AMOUNT
FREQUENCY
DURATION
WHO
WHERE
WASTE HANDLING
7. Duration of use 1 hr 2 hrs 4 hrs 8 hrs 16 hrs 40 hrs 40 hrs
Scheme for Description of use
HOW
RISK MANAGEMENT MEASURES
AMOUNT
FREQUENCY
DURATION
WHO
WHERE
WASTE HANDLING
8. Risk Management Measures - Gloves (physical protection) - Filter and dust mask - Protective coverall - Hood - Gas filter mask - Full face respirator with comb filter - Air-supplied full face respirator - Keeps room ventilated (consumer/professional) - Automatic ventilation (max. m3 air pr l product)
Scheme for Description of use
HOW
RISK MANAGEMENT MEASURES
AMOUNT
FREQUENCY
DURATION
WHO
WHERE
WASTE HANDLING
9.a Waste handling – Empty containers - Disposed of as hazardous chemical waste - Handled as normal household waste - Recycled to supplier 9.b Waste handling – Waste water - Collected and treated as hazardous chemical waste - Discharged via sewer connected to waste water treatment plant. - Discharged via sewer not connected to waste water treatment plant 9.c Waste handling – Other waste containing raw material. - Partly disposed of as hazardous chemical waste - Partly handled as normal household waste - Partly recycled to supplier
Scheme for Description of use
Filling out “Description of use”
Raw material used in wood protection product for professionalspray application at out-door conditions.
Raw material used in decorative product for brush applicationby normal consumers.
. . . . . . . . . .
.
.
.
.
1 2 3 4WhoWhereHowAmount
Independent usages of raw material
.
DU Immediate raw material supplier
Agenda
• Danish REACH project
• Exposure Scenarios and our assumptions
• An example of “Description of Use”
• Further work
Possible future work 1/2
• Make final Exposure Scenarios– Paint– Adhesive
• Collaborate with supplier on raw material to develop right form of Template/Final ES
• Collaborate with ‘Arona network’: “ES is still to be defined in practice”
• Test concept with Technical Service in DU and with customers
Exposure routes
Potential future work 2/2
Environment
Prof. & Industrial
Consumer
Target groups
Water
Soil
Air
En
viro
nm
ent
Hu
man Oral
Skincontact
Inhalation
Amount of materialtransferred todifferent exposureroutes
All usages
THE END
Pilot work (financed by industry)
Companies
Project Organisation
Project work(100% financed by Danish EPA)
Hempel
Dana Lim
Dyrup
30%60%
60%
Hse consult:100% project leader
Ad HocConsultancy workDanish Paint
AssociationResponsible for Project
Pilot companies
• Examples of product types:Decorative, Marine and Anticorrosive PaintsAdhesives; Sealants; Inks and Wood-protection
• Market segments: Consumer, Professional, Industry
• Large variation in size of companies:Local niche companies Nordic based European International
• Most pilot companies have production in Dk• Most pilot companies are Danish owned
Members of associations
Producing members
Pilotcompanies
External complexity – seen from Manufacturer
Manufacturer
DU Company
DU Company
DU Company
Distributor DU Company
DU Company
DistributorDU Company
Soap & Detergents
NailVarnishremover
ProfessionalApplication ofpaint
Substance
External complexity – seen from DU
Distributor
DU Company
Manufacturer
EU
Customer
Raw material Product
Paint & Adh.
BLACK BOX
Manufacturer
Re-brander
Manufacturer
20 raw materialspr. product
DistributorProduction
DistributorEU
Production
DistributorProduction
Paint & Adh.
Coping with external complexity!
Sales office for “mother” company
Distributor (import from outside EU)
Production Company
Distributor(EU based goods)
Functional communicationSupplier
Salesresponsible
Technical Dept. HSE
Paint & Adh.
Purchaseresponsible
R/D HSE
Commercial
Technical
Technical Service
Customer
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