Syska Voskian Consulting

Compliance with REACH at the Workplace

Compliance Assessments

Use of Exposure Scenarios to support the HSE work in European Operations

Prior to REACH, companies with operations within the European Union were “only” required to carry out a Risk Assessment for all situations in the workplace where hazardous chemicals were used or generated.  The Risk Assessment was typically based upon the hazard information contained in the Safety Data Sheet, together with the user’s knowledge of their operating conditions, national exposure limits and other information, as required under the national regulation implementing the Chemical Agents Directive and other workplace safety directives.  These requirements have been in place for many years and should be an integrated part of any company’s existing HSE procedures.

New information on chemical hazards and risks is now starting to show up in the supply chain from industry’s work with REACH, in the form of “Exposure Scenarios” and updated Safety Data Sheets, with much more information available than in the past.

The information contained in the Exposure Scenario as well as possible Authorisations or Restrictions need to be complied with in workplace operations. The employer has an obligation to make use of this new information and to ensure that the Exposure Scenario covers the way the chemical is used by the company. If it is not, the use cannot continue. The risk assessment and the measures that are in place to protect the workers against risks from the chemicals must be in line with the operational conditions and the risk management measures outlined in the Exposure Scenarios.

The information that is communicated via the Exposure Scenarios may be difficult for a company and its HSE organisation to handle: first of all this is a new concept.   Additionally, the structure and level of detail will vary considerably among suppliers, leaving it to the individual company to find ways to understand, manage and make use of the information. Note that each supplier of each chemical will need to provide Exposure Scenarios for each mixture, or each substance in a mixture, so the volume of documents will be significant. There will be situations where the Exposure Scenario requires different actions to be taken compared to what is already in place.  The HSE organisation is required to act upon such a conflict.  There will also be situations where the company has to make notifications to the European Chemicals Agency.

Syska Voskian Consulting offers a unique combination of many years of real-life, hands-on experience on supporting a company’s HSE work to comply with the requirements stemming from the Chemicals Agents Directive and from other directives regarding the use of chemicals at the workplace, plus a very thorough understanding of the Downstream User obligations under REACH including experience with handling information from the Exposure Scenarios.

Summary of our approach:

Training of the HSE group and other relevant groups in the new information flow and requirements to the company under REACH.

  1. Review the company operations and procedures to help set priorities on any needed changes.

  2. Assess if current IT systems are adequate to support company policy and the additional regulatory requirements.

In support of the HSE organisation, understand and structure the information flow, and establish proper documentation of compliance with the new, additional requirements from REACH.