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Use and Exposure - Background Information
Read this page to understand how Shell Lubricants companies are approaching this important element of the Registration process
Find out what our customers need to do on the Use and Exposure - What our customers need to do page.
REACH requires an understanding of how chemical substances are used, specifically, how they are handled throughout their life cycle from manufacture to disposal. For those substances that are hazardous, a risk assessment is required to be performed for each use to demonstrate that it is safe. This is part of the REACH registration process.
For substances we manufacture (for example base oils, process oils, foots oils, aromatic extracts) we are actively working with CONCAWE (the Oil Companies’ European Association for Environment, Health and Safety in Refining and Distribution) who have collated information on product uses for the development of exposure scenarios for use in the Chemical Safety Assessments.
For our blended lubricants (i.e. preparations/mixtures) we have been working with the Technical Association of the European Lubricants Industry (ATIEL) and the Technical Committee of Petroleum Additive Manufacturers in Europe (ATC) who have been working together to identify and collate known information on how these products are used, along with associated operating conditions and risk management measures, and make this available to suppliers and customers of lubricant products via the ATIEL and ATC web sites (Reference 1).
They are also proactively sharing this work with other known Supplier and Downstream User organisations (of which you may be a member) with an interest in the manufacture and use of lubricants. In this way it is hoped to limit the need for unstructured communication up and down the supply chain, in line with the recommended industry model (Reference 2) and provide consistency to how lubricant uses are described.
This group has collated a listing of lubricant applications and associated use descriptor information covering the whole lubricant additives and lubricant life cycle, following the use descriptor system as advised in the REACH guidance
This information, initially in the form of use descriptors and more recently supported by generic exposure scenarios (how the product can be handled safely) together with guidance are available via the following website www.atiel.org .
The ATIEL website provides step by step guidance for all actors in the supply chain and we encourage you to refer to this.
It is targeted at suppliers to the lubricants industry, especially EU manufacturers and/or importers of substances and/or formulated products and to our downstream users (customers). In particular it is aimed at substance manufacturers and importers who need to prepare Chemical Safety Assessments & Reports (CSA/CSR) for REACH registrations and to anyone developing extended Safety Data Sheets (eSDS) for lubricant additives and finished lubricants.
Sections 6 and 7 of the guidance provides clear advice on how Suppliers and Downstream Users within the lubricants supply chain can use the information provided in these web pages (in conjunction with the ECHA guidance if necessary) to ensure that the registration dossiers of substances used in the lubricant industry sector cover all the relevant Identified Uses and aid in the generation of Exposure Scenarios.
The guidance is divided between Suppliers and Downstream Users since it is anticipated that the information will be used differently depending on your position within the lubricants supply chain. It is recognised that individual companies can be both a Supplier and a Downstream User and so might need access to both sections of this site.
Reference 2: As promoted by the European Chemical Industry Council (CEFIC), the Distributors
Association (FECC) and the Downstream Users Association (DUCC). For further details of
the model and exposure scenario development see CEFIC REACH document ‘Guidance on ES development & Supply Chain Communication’.
CEFIC - European Chemical Industry Council
Reference 3: ECHA Reference 12 document
Reference 4: CONCAWE