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More on downstream user responsibilities

More on downstream user responsibilities

When downstream users receive an extended SDS for a substance or mixture, they need to establish whether their use is supported by the exposure scenarios (ES) or safe use of mixture information (SUMI) annexed to the SDS. Formulators also have to consider the foreseeable use of their mixtures by their customers.

To check if their use is supported, downstream users need to:

  1. Gather information on how the substance is used
  2. Establish whether the actual use and conditions of use match the conditions described in the exposure scenarios received.

When the use is supported, downstream users should document the check and provide relevant information on safe use to customers if necessary. When the use is not supported, downstream users have a number of options:

  • implement the conditions of use described in the exposure scenario they have received;
  • make their use known to their supplier and request an updated exposure scenario;
  • substitute the substance with a different substance for which an exposure scenario is not required or where exposure scenarios are available which covers their conditions of use. Alternatively, substitute the process with a process not requiring the substance;
  • find another supplier who provides the substance or mixture with an exposure scenario that covers their use; or
  • prepare a downstream user chemical safety report (DU CSR)

Again, downstream users have to provide information on safe use to their customers, if necessary, and may need to report to ECHA.

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