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1 When will you issue an update to your REACH compliant safety data sheet (eSDS)?

Substances

For the substances that Shell companies have registered in 2010 – a revised eSDS will be available as soon as possible after the Registration deadline.

If we identify a significant change to the information in risk management or classification based on new hazard information – a revised eSDS will be re-issued without delay

Mixtures

For the mixtures we place on the market (e.g. lubricants) – if we receive any information that causes a significant change to the advice provided on our eSDS – we shall re-issue a revised eSDS without delay.

If we do not have any significant new information we will re-issue our eSDS as soon as possible and no later than 1st December 2012 for mixtures comprised of substances registered in 2010

2 Included on some of our products, what does 'exposure scenarios' mean?

What is exposure scenario?
An ‘Exposure Scenario’ describes how a substance can be safely handled to control exposures to both human health and the environment.  The full REACH definition for an Exposure Scenario is as follows:

‘Exposure Scenario’ means the set of conditions, including operational conditions (OC) and risk management measures (RMM), that describe how the substance is manufactured or used during its life-cycle and how the manufacturer or importer controls, or recommends downstream users to control, exposures of humans and the environment.

When are Exposure Scenarios (ES) required under REACH?
ESs are required to be developed for the identified uses of substances that are sold at >10 tonnes per year and are classified as dangerous. If safe use can be demonstrated, the associated ESs will be appended to the extended-Safety Data Sheet (e-SDS). Those uses for which safe use cannot be demonstrated will be identified as ‘unsupported uses’ and also reported in the SDS.

Where appropriate, Shell has prepared ESs for the identified uses of our products as part of the development of our substance Chemical Safety Assessments. These ESs are currently being incorporated into an up-date to our Safety Data Sheets, known as an extended-Safety Data Sheet (e-SDS).

In defining ‘use’ Shell has applied the ECHA Guidance on information requirements and chemical safety assessment, Chapter R12: Use descriptor system.

What should our Customers do on receipt of an SDS containing Exposure Scenarios?
When customers receive an up-dated SDS for a product requiring ESs, they will need to identify the relevant ES (s) for their particular uses. In addition they will need to review the ESs to check whether their local situation is consistent with the operating conditions and risk management measures identified in the ES for the demonstration of safe use.

If a Downstream User’s (DU) use, or the conditions of use, does not appear to be covered, the DU has 12 months (REACH Article 37) from the receipt of the e-SDS to contact the supplier to request that they consider including their use/use conditions in their Registration. In Shell, we have tried to be comprehensive and it is likely that some alignment on the identification of Use is necessary rather than an actual gap.

3 This product is classified as dangerous, why is there no exposure scenario on the eSDS?

Substances

The risk management measures for preventing the health hazards associated with the physical-chemical properties of a substance - such as those classified as R65/H304 (Harmful: may cause lung damage if swallowed/May be fatal if swallowed and enters airways) or R66/EUH066 (Repeated exposure may cause skin dryness or cracking) - are the same regardless of the type of exposure scenario.

For R65 classified substances precautions are needed against ingestion and for R66 precautions against skin contact.

In these cases the advised risk management measures are included within the main sections of the SDS as they are applicable in all circumstances when handling these substances.

Mixtures

For our mixtures – an exposure scenario is only required when we receive information that causes us to change the risk management measures or classification based on new hazard information or when we have received all the exposure scenarios for the risk determining substances.

If there is no ES in the eSDS for this product, then neither of the above criteria has been met.

4 Why are there no Registration Numbers included on this eSDS?

Polymers and other substances exempt from REACH registration do not require a registration number.
For mixtures - there is no requirement to add Registration numbers to our eSDS for all components. We shall be adding the substance specific element of the registration numbers of the hazardous components in our eSDS when we re-issue the eSDS. For the eSDS of a mixture containing no hazardous substances, or containing hazardous substances below the level that triggers a classification of the mixture – then no registration numbers are required.

5 Why have only one registration number on the eSDS when the product contains many components?

Please refer to the answer in Question 3.

6 Why did I receive a eSDS, I have not purchased this product for a while?

This is because we have revised our eSDS and all our customers who have received the product in the last 12 months automatically receive an update.

7 How do I obtain a eSDS in another language?

Please refer to the electronic product catalogue (epc).

8 How do I know that this is the latest version of the eSDS?

Please refer to the electronic product catalogue (epc).

9 The eSDS is very long and complicated, what parts are essential for me to read and understand?

A simple guide to the format and information on the eSDS will be published on this website shortly.