VLARIP Netwerkevent 24 januari 2013
Omgaan met (uitgebreide) veiligheidsinformatiebladen Raf Leyman Regulatory Affairs Manager EMEA
Agenda REACH@Buckman history Buckman REACH Safety Data Sheets (e)sds within Buckman VLARIP Lessons learnt Future challenges 3
REACH@Buckman history Impact of REACH on Buckman on all 3 levels defined by REACH : as manufacturer of substances as importer of substances (BL affiliates, non-eu suppliers) as downstream-user of substances 4
REACH@Buckman history REACH Team Buckman Europe Main contacts : General REACH e-mail: reach@buckman.com Raf Leyman Regulatory Affairs Manager rleyman@buckman.com Tim Hayaert Regulatory Affairs Coordinator - REACH thayaert@buckman.com 5
REACH@Buckman history Follow-up on legislation Industrial associations: CEFIC - Brussels (European Chemical Federation) essenscia - Brussels (Belgian Chemical Federation) Member of VLARIP projects 1 & 2 Theme meetings 6
REACH@Buckman history Preparing for REACH at Buckman Substance Inventory Pre-registration Decision making registration Mapping of uses (DU)... 7
REACH@Buckman history Preparing for REACH at Buckman Internal communication Depending on issues related to REACH and publication of different Guidance Documents => involvement of Supply Chain, Production, Sales/Marketing Management, Technical Management, IT, Finance, Regulatory Affairs, Buckman affiliates, => Create ad-hoc working groups => Create global REACH Team 8
Buckman REACH Safety Data Sheets SDS software upgrade project (2009-2011) : December 2010 : SDS according to new REACH Annex II format (EC453/2010) for substances and for new or updated preparations September 2011 : launch of all SDS according to new REACH Annex II format (EC453/2010) for all marketed mixtures, with anticipated CLP clas sification in section 16 9
Buckman REACH Safety Data Sheets Mixtures: Section 16 contains the anticipated CLP classification (not legally binding)
(e)sds within Buckman DU Main Obligations (ECHA Guidance for DU 1.1.) 1. Follow instructions in SDS + exposure scenario(es) If use not covered by ES: Contact supplier Own CSR 2. Contact supplier when new information on hazards is available or when RMM s are unappropriate 3. Provide customers information on hazards, safe conditions and RMM s
(e)sds within Buckman How to handle first e-sds 140 pages?!? everyone@buckman : curious to see, but afraid to read Vlarip theme meetings on Reading e-sds Goals & expectations : Reading & understanding Implementation in the company Communication Downstream
(e)sds within Buckman Action points (Themafiche Vlarip extended SDS) Check if substance has been registered RRN Analyse SDS for new data (RA + OPS + SHEQ) Check if our uses are corresponding to the ES s If not: Contact supplier Implement RMM s and OC s Stop use of material Communication Downstream of new info Communication!
(e)sds within Buckman Kick off meeting December 7 2011 Goals : 1. Awareness of e-sds concept 2. Legal obligations 3. Impact on different departments 4. Establishing workflow 5. Assigning responsibilities
(e)sds @ Buckman flow created based on draft Cefic doc Process in companies after receiving an (extended SDS)
(e)sds @ Buckman RA + PUR + LAB + OPS + SHEQ + PM + FSC
(e)sds within Buckman Further approach in handling e-sds : Gathering/Assign date of receipt of all e-sds + determine 12-month dead-line Evaluated prioritised e-sds Continue learning process following Vlarip e- SDS Theme meetings, involving Process Engineer
VLARIP Lessons learnt Pragmatic approach Involve right people New parameters on ES related to default values used in models (e.g. LEV 95% efficient) Scaling requires expertise Communication with your supplier = important Evaluation of OC s & RMM s was already required before Use of Vlarip tool : Compliance check ext-sds
VLARIP Lessons learnt Use of Vlarip tool : Compliance check ext-sds Example NEP Communication with your supplier = important Example
VLARIP Lessons learnt Procedures in place : 1. NPIP New Product Introduction Procedure 2. SDS flow incoming new/updated SDS 3. LC flow impact on Buckman SDS
Future challenges Continue the Learning Curve Optimisation of e-sds flow e-sds of most RMs still to be expected RMs = low volume + mixtures e-sds for mixtures Follow Theme meeting Expert judgement required Pragmatic approach required
REACH... A never ending story? Continue the Learning Curve... final prep + submission REACH 2013 dossiers queue of 2018 applicants, not being actively involved yet in REACH process of which a lot of SME s PROCESS OF CONTINUOUS SUPPORT REQUIRED
REACH... A never ending story? VLARIP 2-project comes to an end REACH still ongoing for some time Industry still needs further assistance... VLARIP... A never ending story!!!