The GTS REACH working group meets in Unterschleissheim

Werner Krömmer

On 5 March, the GTS REACH working group met for the fourth time. On a topic which is of great importance to all of us, the aim was to exchange previous experiences, to stay up to date and not miss any urgent deadlines. At the GTS Annual General Meeting 2008 and in previous issues of GTS-Strahl/TS-Bulletin, we already reported on the initial work which has been carried out. The steps for the user had more of an internal relevance at the start. Here, the most significant step, i.e. to compile a substance inventory from this information, should now help everyone to proceed in an organized manner. Both coating businesses and powder suppliers can make the use of their spray materials known by 31 May 2012. This step is important to ensure that the applications of coating businesses are listed in the new safety data sheets and that the coater does not end up in a one-way street.

According to Article 37 of the REACH Regulation, it is not an absolute must to notify the manufacturer, importer or the downstream user who supplies the substance about one’s own application. But only in this way can the former prepare an exposure scenario or, if necessary, a use and exposure category within his substance safety assessment.

The importance of this step becomes clear when we continue along the timeline: if the use is not listed in the safety data sheets, the substance may no longer be employed for that use, and this means until this time-intensive process is finalized. Furthermore, the user must bear the extremely high costs for this process. A circular will be sent to all GTS members summarizing the most important points. This will include a letter to the supplier which is formulated as simply as possible but contains all the relevant details.

REACH – Form for submitting substance use in download section