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REACH case studySimpler distribution of Safety Data Sheets

Businesses in the paint industry experience regulatory pressure in drawing up and

distributing Safety Data Sheets (SDSs) for hazardous substances. Within the REACH

case study of Slim geregeld, goed verbonden (Sggv Smart Arrangement, Solid

Connections) industry and government authorities in the Netherlands are working

together to reduce this regulatory burden.

REACHThe European REACH regulations govern chemicals and their safe use, requiring any businessmaking a first delivery of a hazardous substance or mixture (preparation) to another companyto also supply a material Safety Data Sheet (SDS). This sheet contains information about therisks and protective measures that must be taken when working with the product (for exampleventilate well and wear gloves and breathing mask), as well as information about first aid, firefighting, the physical/chemical characteristics of the substance, storage, etc. When an SDS isrevised, the supplier must send a copy of the new Safety Data Sheet to its customers.

BottleneckIt turns out that small paint companies spend three times as much time on producing SDSs ascompared with large manufacturers. Unlike large paint companies, they do not have a specialsoftware application for drawing up SDSs, but carry out the work manually or insource aspecialist firm.

The distribution of SDSs also generates considerable administrative burdens in all companies,large and small. An SDS may be distributed digitally (via e-mail). However, the distributionobligation upon the supplier requires more than simply a reference to a website where the SDScan be viewed. An e-mail including a Pdf attachment of the SDS or a deeplink to the correctSDS published on a website, is sufficient.

The highest level of regulatory burden affects paint dealers (wholesalers and distributors) since

their role is to sell a wide range of different products from a variety of suppliers. Ensuring thatthe correct SDS always reaches the intended customer results in a great deal of administrativework.

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Case study REACH 2

The business case drawn up in collaboration with the paint industry reveals that it is possible toachieve a reduction of almost 700,000 on the estimated annual regulatory burden of 1.3

million for SDSs in the paint industry. For all industries in the chemical sector the estimatedregulary burden caused by REACH measures 9 million annually. A reduction of 2.8 million ispossible.

Chain partnersChain partners from industry and government are working together on reducing regulatoryburdens within the chain. Raw material suppliers, paint formulators, wholesalers/distributorsand professional end users such as house painters are included in the case study via theirsector organisations. At the same time, the departments responsible for legislation andenforcement in respect of hazardous substances are involved in the REACH case study. Thesteering committee is made up of the sector organisations VNCI (for the chemical industry),VVVF (for the paint and printing ink industry), VVVH (the association of paint product traders),Fosag (the sector organisation for house painting companies) and the government departmentsfor Infrastructure and the Environment, Social Affairs and Employment, and Economic Affairs.The chairman is Han Somsen, professor in European environmental law.

SolutionThe chain partners have been investigating how to solve the bottlenecks in the implementationof REACH for product safety data sheets in the paint chain. Priority was given to the distributionof the data sheets. To solve this bottleneck, an ICT solution (prototype) was built and tested,under the supervision of Sggv. The prototype helps transfer supplier information from the salesorder system of a distributor of paint products, to the website veiligmetverf.nl. This websitebrings together the product safety data sheets of practically all hazardous paint products. The

website veiligmetverf.nl then sends an e-mail containing the relevant data sheet to thepurchaser. As a consequence, the distributor no longer needs to send an e-mail to everycustomer containing the relevant product data sheet. This application saves the distributor agreat deal of administrative red tape, thereby substantially reducing regulatory burdens.

Completion and follow-upUpon completion of the case study on 7 December 2012, the chain partners decided to take onboard the Sggv initiative. During the final steering group consultation meeting, they dulysigned a declaration of intent.

In 2013, the chain partners will implement the tried and tested solution. The paint sector aimsto optimise the automated distribution of product safety sheets. The paint wholesalers will beimplementing the process during the first quarter of 2013. Within the paint sector, theapplication will generate an annual saving of 520,000. The Association of Paint and PrintingInk Manufacturers (VVVF) and the Association of Paint Traders (VVVH) aim to further follow upthe initiative throughout the paint sector.

The automated distribution of product safety data sheets could also generate considerablesavings in other sectors within the chemical industry. Possibilities include soap products andcleaning agents as well as adhesives and cements. VNO-NCW (the employers organisations)together with the Association for the Dutch Chemical Industry (VNCI) will be coordinating thisbroadening of the scope of the application. Introduction of a similar application within otherchemical sectors could generate an annual saving in the order of magnitude of 1.1 million euro.

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Case study REACH 3

About Sggv

The Slim geregeld, goed verbonden (Sggv) programme supports public-private chains insubstantially reducing regulatory pressure for businesses and improving efficiency in service bygovernment authorities. The commissioning party is the dutch Ministry of Economic Affairs. Formore information about the Sggv programme, surf to www.sggv.nl.