A brief REACH overwiev for distributors
As a distributor you are obliged to pass the information from one actor of the supply chain to another relating to the goods you turn over. This extends to the safety data sheets of substances and preparations aswell.
In addition, certain information are to be supplied to the required materials, products or commodities, if the safety data sheet is not mandatory. You are not the downstream user of materials/preparations under REACH, but you play a dominant role in the flow of information in the supply chain. In principle you have a similar role before the role of REACH.
Therefore the transmission of information within the supply chain can be used from previous experiences and methods within the scope of REACH.
You can stimulate the preparatory measures in the initial phase of REACH. This you can do by stimulating the communication between the manufacturer or importeur of the materials and you customer – who are often the downstream user.
The preparation manufacturer or the end user of the substance or preparation, that is the end user is entiteld to describe the supplier the purpose of making utilization to identified utilization. The description of the own utilization (utilizations) should also be provided to the supplier.
The downstream user may also decide to prepare his own chemical safety assesment of the material/preparation for own or customer utilization. This is important, for example when you want to handle the utilization confidentially or the vendor does not intend to supply a particular use. It is possible the the downstream user cannot carry out a chemical safety assesment by the grounds of the information on the safety data sheet or the exposure scenario given to him; he might need further information from the vendor, such as hazardous properties of the material or the exposition assesment; this means the application of assumptions and exposure assesment tools regarding the conditions of utilization.
This additional information relates mainly to the exposure assesment; this means the terms of utilization and the assumptions of exposure assesment tools.
If this is the case, your role as distibutor is the transfer of request for information to your vendor and the transfer of the vendors answers to the downstream user.
The distributors obligation of the information transfer
According to REACH, you are obliged to transfer the information in the supply chain. It is possible that you have direct contact to the material/product manufacturer/importeur and to the end user, but the supply chain may contain other actors, when you, as vendor are located between two end users.
The type of the transmitted information can be as follows:
- Identifying information of the utilization, from the manufactourers/importeurs to the downstream users trough questionnaries or from the downstream users to the vendors a brief, standard description of the utilization
- Specific information from the downstream user, who attends to make a downstream user chemical safety report
- Safety data sheet with and without exposure scenario
- Information regarding the approval of the material
- Particular information on hazardous substances in an article.
You may have to document, that you have recieved information from the wendor and that you transmitted the information to other actors of the supply chain.
It is therefore recommended that you send the information for the vendors and consumers written on paper or electronically.
Regarding obligations under REACH, the communication procedures and the handling of documents can be described and booked as a part of your quality system.
It is important, that the distributor the information regarding the material/preparation after the last delivery at least for 10 years stores (REACH Article 36.)