Checking and implementing the exposure scenario

REACH knowledge base – Checking and implementing the exposure scenario

1. Checking the description of use

If the description of use differs significantly from the intended use of the downstream user, the downstream user must contact the supplier in order to clarify the situation.

2. Checking the method of use

If the intended use of the substance or mixture results in higher exposure than that covered by the exposure scenario, the downstream user may not be in compliance with the exposure scenario and should therefore contact the supplier.

3. Checking the risk management measures

These recommendations should be compared with the measures we apply to protect workers, consumers and the environment. It is necessary to determine whether these measures are the same as, or more effective than, those proposed in the exposure scenario. The supplier should be informed if we consider the proposed risk management measures inadequate.

Differences between the conditions of use in practice and those described in the exposure scenario do not always mean that the use is not covered by the exposure scenario. If the operating conditions are the same as those described in the exposure scenario, or are similar to them, and the relevant quantitative values are within the specified limits, the exposure scenario applies.

Tasks to perform when the substance used has been registered, but its exposure scenario does not include our specific use

Describe our use to the supplier in order to obtain an exposure scenario that also covers our use.
Change the conditions of use to comply with the conditions of the supplier’s exposure scenario.
Look for a supplier whose exposure scenario covers the intended use.
Prepare our own chemical safety report.
Substitute the substance with another one or change the technology.
Suspend the activity.

Substances or mixtures incorporated into articles

The chemical safety report of the registrant must cover all life-cycle stages of the article and, where applicable, the service life of the article, as well as its waste stage and the relevant exposure scenario.

As a downstream user, we only need to check the steps that apply to us and those stages of the article life cycle that are relevant to us. It is not our task to determine whether the subsequent actors in the supply chain meet the requirements.

If necessary, information on safe disposal should also be provided with the articles.

Documentation

The evaluation of the conditions of use described in the exposure scenario, and compliance with them, should be documented.