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SAFETY IN THE PLANT 


Fig. 1. REACH affects companies throughout the world, similar legislation is now being considered in other countries, most significantly in the US.


Next steps for REACH Compliance T


 With the REACH registration of high volume and hazardous chemicals now complete, many companies will now be turning their attention to the next phase of compliance which involves the production and delivery of Safety Data Sheets. Malcolm Carroll reports.


 L’enregistrement REACH des produits chimiques en grand volume et dangereux étant désormais achevé, de nombreuses sociétés tournent leur attention vers la prochaine phase de conformité, laquelle implique la rédaction et la remise de fiches Santé Sécurité. Malcolm Carroll rapporte.


 Nach Abschluss der REACH- Registrierung großer Volumen und gefährlicher Chemikalien richten viele Unternehmen nun alle Augen auf die nächste Phase der Konformität: die Ausfertigung und Bereitstellung von Sicherheitsdatenblättern. Ein Bericht von Malcolm Carroll.


o comply with REACH, any company involved in importing and distributing oil to and within the EU will need


to ensure the direct delivery of Safety Data Sheets (SDSs) and associated documentation to customers. They will also need to ensure SDSs are kept up to date, that customers can provide validation of their delivery, that they are using the most current SDSs throughout their organisation and that they have sufficient audit capabilities. To achieve compliance in this area is a


huge administrative challenge and could also prove incredibly costly. As SDSs are needed at every stage of the supply chain, this issue will impact thousands of companies. New methods of delivering SDSs and


associated documents will be required as traditional methods will prove unacceptable, expensive and they will not be robust enough to meet the REACH compliance requirements. REACH compliance insists SDSs must be


supplied directly to the customer so there are some obvious problems with current working practices in this areas. If we look at each of in turn, there are some very real challenges.


❒ Email does not guarantee or record proof of delivery without significant time, effort and cost and obviously does not physically replace old, out of date versions of an SDS.


13 ECE


❒ Post has the same problems as emails, adding further costs and time with stationary, postage and administration.


❒ Placing documents onto a website simply will not suffice as it provides no proactive delivery and is already rejected by REACH.


Nor will existing methods help with the intent of REACH, as customers will not be alerted to any changes in the SDSs, multiple recipients are not easily managed and there are no standards in terms of the media on which the SDS is held, making easy and consistent access difficult. All of this results in either significant additional costs for suppliers or the possibility of errors leading to non-compliance with the regulations. So the issues facing companies are


significant and there are many questions that companies now need to address. How do they fully comply with the legislation in respect of the delivery and receipt of SDSs? How do they maintain their operations and ensure only the use of current information, and provide consistency across all operational areas? How do they effectively audit, internally and externally, and prove the delivery, receipt and access of critical information by customers? And, how do they address possible legal action should it arise?


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