Information in the Supply Chain
A good flow of information up and down the supply chain is a key feature of REACH. Users of chemicals need to know and understand the hazards involved in using chemical products and how to control the risks. Manufacturers and importers of chemicals must supply this information on the hazards and risks to downstream users and distributors. However, in order for suppliers to be able to assess these risks they need information from the users about how they are used. REACH provides a framework in which information can be passed both up and down the supply chain and Title IV of the REACH regulation deals with the duties and obligations to provide the relevant information in the chain.
The two main instruments used to communicate the hazards of substances and preparations are labels and safety data sheets. Provisions for labels are regulated by CLP Regulations and by Regulation (EC) No. 1272/2008 (CLP) which will be introduced over a phased period running until 1st June 2015. The label is the primary tool for communication of hazard information to the consumer whereas the safety data sheet provides more detailed information on hazards and control measures for the worker. Safety Data Sheets should accompany chemicals through the supply chain, providing information to users in order to ensure that the chemicals are safely managed.
Workers access to information
All workers and their representatives must have access to the information given in safety data sheets for those substances or preparations that they use or have the potential to be exposed to while at work. Where safety data sheets are not required but substances either on their own or in preparations are subject to authorisation or restriction, then this information must be made available to all workers and their representatives.
Duty to keep information
Every manufacturer, importer, downstream user and distributor has a duty to gather and keep all information relevant to their obligations under REACH for a period of at least 10 years after they last manufactured, imported, supplied or used the substance or preparation. They are obliged to make this information available without delay when requested to do so to any Competent Authority of the Member State in which they are established or to the European Chemicals Agency (ECHA).