- Project number: F 2415
- Institution: Federal Institute for Occupational Safety and Health (BAuA)
- Status: Completed Project
Description:
The project examined data availability and information flow between registration dossier, (extended) safety data sheet ((e)SDS) and workplace risk assessment at the interface between the requirements of the EU chemicals regulation REACH and occupational safety and health (OSH). The focus was on how missing, inconsistent, or insufficient information and the quality of the information flow may affect workplace risk assessment and subsequently OSH.
The used methods were: (1) Assessment of availability and quality of information in the Chemical safety Report (CSR) of substances registered in the tonnage band of 100-1000 tonnes per year. (2) Investigation of translation of exposure information and risk management measures (RMM) from the registration dossier to (e)SDS. (3) Examination of the sufficiency of available data in (e)SDS to perform a reliable workplace risk assessment using the workplace risk assessment tool ‘EMKG Workplace & Chemicals'.
The majority of the CSRs and (e)SDSs analysed in this project show deficiencies with regard to the legal information requirements. It was noted that even in cases where the CSR has been assessed as compliant, there were deviations and shortcomings in the (e)SDS. However, there were also cases where a CSR assessed as non-compliant had a corresponding (e)SDS of much higher quality. In addition differences in labelling and classification information between the registration dossier and the (e)SDS were observed. These inconsistencies may affect the identification and the implementation of appropriate protective measures at all supply chain levels. The results were used to develop approaches to improve the communication of risks and measures in the supply chain. One way to avoid such inconsistencies in the future would be a technical adaptation of ECHA's IT tools to allow automatic generation of (e)SDSs from registration data. Regarding the usefulness of exposure scenarios as extension of SDS for workplace risk assessment, there is a clear need for improvement especially with respect to the conditions of use provided and the recommendation of application-specific RMM for the safe design of workplaces and activities. We recommend that in order to avoid deviations and inconsistencies in the recommended RMM in advance the hierarchy of control measures, a legal requirement and well-established concept in OSH, should already be taken into account during the chemical safety assessment under REACH. This can also increase the benefits for users and create legal clarity. Further recommendations include the introduction of a binding, harmonised format for exposure scenarios with a stronger focus on target groups.
