Monday, November 24, 2008

EU REACH Directive - Chemical Users Responsibilities

Although the burden of risk evaluation and control is placed on the manufacturers and importers, REACH does include requirements that apply to USERS of regulated materials. The risk assessment process used to register materials is based on specific uses and mitigations. Therefore, the User requirements assure that mitigation measures are actually used, and that any new uses of materials, which were not included in the risk assessment, are evaluated.

To accomplish this, Users are required to

  • Use materials only for labeled uses
  • Understand and use all risk mitigation measures incorporated into the manufacturers risk analysis

If Users of materials wish to have new uses, they have two options available:

  1. They can inform their manufacturer or supplier of the new uses and request that the new uses be added to the list of recognized uses (which may require further risk assessment)
  2. They can perform and submit their own risk assessment on the new use

For further information contact Caltha LLP at
Caltha LLP Website

No comments: