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Cross-industry compliance effort

Shell product stewards, industrial hygienists and even legal experts played a key role in cross-industry bodies created to ensure the successful registration of products under the European Union’s REACH chemicals regulation.

The preparation of safety dossiers has been a massive task, involving an unprecedented level of cross-industry cooperation

David Owen, Shell Chemicals Advocacy Manager

Registrations are a significant milestone in the implementation of REACH as they involve the preparation and submission of comprehensive safety dossiers for each chemical substance and its end-uses. The dossiers describe the physical properties and hazards associated with a substance, and how and where it can be used safely throughout the supply chain.

“The preparation of safety dossiers has been a massive task, involving an unprecedented level of cross-industry cooperation,” says David Owen, Shell Chemicals Advocacy Manager. “It has required the chemicals industry to come together, embrace new ways of working and sharing information, to find the most cost effective and workable route to compliance with a complex regulation.”

Shell has been instrumental in shaping the infrastructure and mechanisms that allowed producers to work together through product consortia, and find common agreement on the preparation and content of safety dossiers.

Shell Chemicals Product Stewards took leading roles in many of the consortia, while the Shell legal team was responsible for helping develop the legal framework for creating and running these new industry bodies. “Before we could even start collating scientific data, ‘rules of engagement’ had to be established under which co-producers could work together, manage intellectual property and spread the cost burden,” says Owen.

John Greenhough, Global Product Steward Solvents

John Greenhough, Global Product Steward for Solvents, was involved in six different consortia formed for solvents with similar technical properties or hazard profiles. “The solvents sector had some of the most complex supply chains and issues to work through,” he says. “Although most consortia evolved out of existing trade associations we still needed a step-change in the way these groups worked and took decisions.

“We had to find smart ways to share the workload, establish a value for the contribution of individual producers, maintain confidentiality of proprietary information and stay within the boundaries of competition law.”

Product consortia also drew on Shell’s expert resources to support the development of exposure scenarios and handling guidelines for the safety dossiers. These included subject matter experts in chemical composition, toxicology, environmental toxicology and industrial hygiene.

Alison Margary, a Senior Industrial Hygienist from the Shell Health organisation, chaired a CEFIC task force formed to establish a standardised approach and framework for developing generic exposure scenarios for groups of similar chemicals.

“From the outset it was clear the industry needed an overarching strategy that would address the ‘mind-boggling’ complexity and enormity of the task to assess the risks and hazards associated with every substance and use,” she says.

“By establishing generic exposure scenarios for substances with common properties or risk profiles, consortia could start to extrapolate appropriate risk management and safe handling guidelines for thousands of substances.”

Shell’s input led to the development of the first generic exposure scenario for the chemical solvent MEK (methyl ethyl ketone), which acted as a pathfinder for other products.

As a result of these efforts all of the required REACH registrations for Shell Chemicals products were completed ahead of the November 30, 2010 deadline.

For a list of registration numbers and up-to-date information on the availability of new REACH-compliant Safety Data Sheets please visit: www.shell.com/chemicals/reach.

This feature was added to the Innovations section in January 2011