sheet ( SDS ) supplied was different to that held in the UK REACH registration database . Divergence of data could be a major obstacle to them in carrying out their duty of care .
The scenario of having different sets of data being submitted to the regulator and being disseminated down the supply chain could obviously cause confusion in communicating hazards , Hollis and Biring agreed . Lubrizol , the latter said , has already used publicly available data in SDSs but there is a quite different issue when it comes to submitting data to regulators .
Patel added that this already an issue in UK REACH . “ A lot of the SDS and eSDS information we have comes from EU REACH registration dossiers , so naturally it ’ s at a higher volume , a lot more information has gone through it and there ’ s a lot more information in the SDS ,” she said .
“ If you do that same UK REACH registration at a lower tonnage , the level of information you need is different . Then your SDS output is going to be different too . That issue is going to be there whatever model of UK REACH we end up with .”
Use and exposure
Use and exposure in the GB context are other common issues when discussing the ATR , Hollis noted . EU regulators have identified shortages of information on these in some areas and are asking for more granular data . UK regulators are now doing likewise .
For Patel , prioritising data based on use and exposure is a positive step . A challenge , however , will be the amount of data that can be collected from the supply chain . EU ( e ) SDSs have been compiled conservatively because it is not always possible to collect that level of granularity , let alone for 20,000 substances . It would be better to do this for “ a more focused , prioritised set of substances ,” she suggested .
Acknowledging that the data will be hard to obtain , Alexander nonetheless argued that the UK would need to meet some obligations that are in the EU pipeline . This will require registrants and DSUs to supply more information . ChemTrust would want to see the evidence that use and exposure really is different in the UK , as one would assume that it would be very similar to the EU .
Given that some large companies like BASF sell hundreds of different products to many companies every day , the question arises of where the onus lie should lie for communicating all the extra information that might be generated . UK and EU REACH both presume that it is the registrant ’ s duty , whatever the precise details may be , Abrahams noted .
30 SPECIALITY CHEMICALS MAGAZINE ESTABLISHED 1981