Andrea Franklin is a Health and Safety Adviser for a medium sized business, Marine Specialty Chemicals Limited, which produces additives for the oil and gas extraction industry. Their main product line is the formulation of water treatment products.
Andrea already knows about REACH and has compiled an inventory of all of the substances her company uses. In doing so she has found it necessary to consult widely in the company.
Most of the chemicals the company uses to formulate its products with are used in conventional ways and Andrea will check with Marine’s suppliers these uses will be included in the registration. For one of their most profitable product types, the company take a formulation made by another company and adds extra components to it. This makes the final product suitable for use in a marine environment. However, on talking to colleagues, she discovers that the research team have spent several years developing this new formulation and they are concerned that if their supplier knows of this use, they will be able to reproduce it which may have implications for the sustainability of this line of business.
Following discussions with her Managing Director, Andrea decides not to inform her supplier of this novel use. She is aware that this will mean that the use will not be supported by the supplier and therefore Marine will have to inform the European Chemicals Agency (ECHA) of this use. They may be required to perform a Chemical Safety Assessment (CSA) of their own. On further research of the REACH text, Andrea identifies several criteria under which a CSA is not required. She discovers, however, that none of these criteria are applicable to this situation and hence she will have to prepare a CSA when the substance is registered. She is aware that she will be able to draw on information from the company’s existing COSHH assessment but she will also need to include consideration of the environmental aspects and exposure scenarios.