REACH knowledge base – Checking and implementing the exposure scenario
If the description of use differs greatly from what the downstream users wish to use the substance for, they have to contact the supplier in order to clarify the situation.
If the substance or mixture results in increased exposure regarding the intended use, the downstream user may not be in compliance with the exposure scenario and should therefore contact the supplier.
These recommendations should be compared with the measures we are taking to protect workers, consumers and the environment. It is necessary to determine whether these measures are the same or more effective than those proposed in the exposure scenario. The supplier should be informed if we consider their proposed risk management measures inadequate.
The differences between the conditions of use in practice and the ones described in the exposure scenario not always mean that the use is not covered by the exposure scenario. If the operating conditions are the same as described in the exposure scenario or are similar to those in the exposure scenario and the given quantitative values are within the specified limits, the exposure scenario applies to them.
The chemical safety report of the registrant must contain all life cycles of the article and, where applicable, also the lifespan of the article, as well as its waste state and the relevant exposure scenario.
As a downstream user, we can only check the steps apply for us and those steps related to the lifecycle of the article that are relevant to us. It is not our task to determine whether the next members of the supply chain meet the requirements.
If necessary, information on safe disposal should also be provided along with the articles.
The evaluation of the conditions of use described in the exposure scenario and compliance with them should be documented.