REACH case study

Simpler distribution of Safety Data Sheets

Businesses in the paint industry experience regulatory pressure in drawing up and distributing Safety Data Sheets (SDSs) for hazardous substances. Within the REACH case study of Slim geregeld, goed verbonden (Sggv Smart Arrangement, Solid Connections) industry and government authorities in the Netherlands are working together to reduce this regulatory burden.
REACH The European REACH regulations govern chemicals and their safe use, requiring any business making a first delivery of a hazardous substance or mixture (preparation) to another company to also supply a material Safety Data Sheet (SDS). This sheet contains information about the risks and protective measures that must be taken when working with the product (for example ventilate well and wear gloves and breathing mask), as well as information about first aid, fire fighting, the physical/chemical characteristics of the substance, storage, etc. When an SDS is revised, the supplier must send a copy of the new Safety Data Sheet to its customers. Bottleneck It turns out that small paint companies spend three times as much time on producing SDSs as compared with large manufacturers. Unlike large paint companies, they do not have a special software application for drawing up SDSs, but carry out the work manually or insource a specialist firm. The distribution of SDSs also generates considerable administrative burdens in all companies, large and small. An SDS may be distributed digitally (via e-mail). However, the distribution obligation upon the supplier requires more than simply a reference to a website where the SDS can be viewed. An e-mail including a Pdf attachment of the SDS or a deeplink to the correct SDS published on a website, is sufficient. The highest level of regulatory burden affects paint dealers (wholesalers and distributors) since their role is to sell a wide range of different products from a variety of suppliers. Ensuring that the correct SDS always reaches the intended customer results in a great deal of administrative work.

The business case drawn up in collaboration with the paint industry reveals that it is possible to achieve a reduction of almost 700,000 on the estimated annual regulatory burden of 1.3 million for SDSs in the paint industry. For all industries in the chemical sector the estimated regulary burden caused by REACH measures 9 million annually. A reduction of 2.8 million is possible. Chain partners Chain partners from industry and government are working together on reducing regulatory burdens within the chain. Raw material suppliers, paint formulators, wholesalers/distributors and professional end users such as house painters are included in the case study via their sector organisations. At the same time, the departments responsible for legislation and enforcement in respect of hazardous substances are involved in the REACH case study. The steering committee is made up of the sector organisations VNCI (for the chemical industry), VVVF (for the paint and printing ink industry), VVVH (the association of paint product traders), Fosag (the sector organisation for house painting companies) and the government departments for Infrastructure and the Environment, Social Affairs and Employment, and Economic Affairs. The chairman is Han Somsen, professor in European environmental law. Solution The chain partners have been investigating how to solve the bottlenecks in the implementation of REACH for product safety data sheets in the paint chain. Priority was given to the distribution of the data sheets. To solve this bottleneck, an ICT solution (prototype) was built and tested, under the supervision of Sggv. The prototype helps transfer supplier information from the sales order system of a distributor of paint products, to the website veiligmetverf.nl. This website brings together the product safety data sheets of practically all hazardous paint products. The website veiligmetverf.nl then sends an e-mail containing the relevant data sheet to the purchaser. As a consequence, the distributor no longer needs to send an e-mail to every customer containing the relevant product data sheet. This application saves the distributor a great deal of administrative red tape, thereby substantially reducing regulatory burdens. Completion and follow-up Upon completion of the case study on 7 December 2012, the chain partners decided to take on board the Sggv initiative. During the final steering group consultation meeting, they duly signed a declaration of intent. In 2013, the chain partners will implement the tried and tested solution. The paint sector aims to optimise the automated distribution of product safety sheets. The paint wholesalers will be implementing the process during the first quarter of 2013. Within the paint sector, the application will generate an annual saving of 520,000. The Association of Paint and Printing Ink Manufacturers (VVVF) and the Association of Paint Traders (VVVH) aim to further follow up the initiative throughout the paint sector. The automated distribution of product safety data sheets could also generate considerable savings in other sectors within the chemical industry. Possibilities include soap products and cleaning agents as well as adhesives and cements. VNO-NCW (the employers organisations) together with the Association for the Dutch Chemical Industry (VNCI) will be coordinating this broadening of the scope of the application. Introduction of a similar application within other chemical sectors could generate an annual saving in the order of magnitude of 1.1 million euro.

Case study REACH

About Sggv The Slim geregeld, goed verbonden (Sggv) programme supports public-private chains in substantially reducing regulatory pressure for businesses and improving efficiency in service by government authorities. The commissioning party is the dutch Ministry of Economic Affairs. For more information about the Sggv programme, surf to www.sggv.nl.

Case study REACH