What's safe use data for non-EU/India

UK: Indian companies requested to provide information on Substances of Very High Concern (SVHC) under the REACH (Registration Evaluation Authorisation and restriction of Chemicals) Regulations might be wondering what has hit them.

As a minimum, they will be asked for the name of the SVHC in the articles (strange REACH word for products) that they supply. They will also be asked to provide, where appropriate, Safe Use Data.

So, what kind of content should be included in the Safe Use Data?

The European Chemicals Agency (ECHA) has issued comprehensive guidance on this important subject, which is a legal obligation for manufacturers and downstream users in Europe. It differentiates between advice to consumers and professional users.

For example, consumers might be advised to keep a substance out of the reach of small children, avoid dermal exposure by not wearing certain clothing in direct contact with the skin, or handle waste as hazardous waste.

Professionals could be warned against dust inhalation from grinding, ensure appropriate personal protection is used, and avoid leakage to the environment if using a product outdoors in the rain.

A typical safety checklist could be:

* Exposure controls/personal protection

* Handling and storage

* Disposal consideration

* Fire fighting measures

* Transport information

Information could be included in safe use, or instructions for use data, and labels may be required in some cases.

Simply linking to websites without clear instruction of where to find the product level information and safe use data would not be deemed sufficient in Europe. Indian companies could find the importer very persistent as the obligation to provide this information downstream then falls upon them.

The author is Customer Support Manager - Legislation and Environmental Affairs, Premier Farnell, UK.