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Dow and REACH - Is Your Use Covered?


Communicating uses

Dow communicates Identified Uses of its registered substances by means of the Safety Data Sheet (SDS) for the products corresponding to these substances (section 1.2). Figure 1 shows an example of section 1.2 of the SDS for a Dow product corresponding to a registered substance.

Figure 1: example of section 1.2 of the SDS

For products corresponding to classified registered substances the SDS will contain an attachment with Exposure Scenarios (extended SDS). Section 1 (title section) of the Exposure Scenario will provide more detailed information on the Identified Use (e.g. the relevant combination of use descriptors). Figure 2 shows an example of such a title section.

Section 1 Exposure Scenario Worker
Title Manufacture of substance
Sectore of Use SU3, SU8, SU9
Process Category                       PROC1, 2, 3, 4, 8a, 8b, 15
Product Category n/a
Article Category n/a
Environmental Release Category ERC1
Specific Environmental Release Category CEPE SPERC 5.1b.v1
Processes tasks, activities covered Manufacture of the substance or use as a process chemical or extraction agent. Includes recycling/recovery, material transfers, storage, maintenance and loading (including marine vessel/barge, road/rail car and bulk container), sampling and associating laboratory activities.
Section 2 Operational conditions and risk management measures
Product/article characteristics
Physical form of product/article Liquid
Volatility Liquid, vapour pressure < 0.5 kPa at STP
Dustiness n/a
Concentration in a preparation/product(wt.%) < 100
Other product/article characteristics None identified


Figure 2: example of a description of a Dow Identified Use

Checking your use

Cefic has developed guidance on how to communicate on uses in the supply chain. The Cefic document provides detailed information both on how to check your use and how to check your use conditions. We recommend you to download this guidance document and follow the recommendations. The Dow guidance is limited to checking your use (not the use conditions) and is in line with the recommendations by Cefic.

When checking whether your use is covered, first try to describe your own use yourself, in text and/or by using the Use Descriptor System, or check whether such a use description for your application is available at the website of your sector organization. Then compare your use description and/or use descriptor combination (or the one from the sector organization) with Dow’s description of use. Below you will find some guidance on how to describe your own use (also refer to figure 3) and/or how to read/interpret the description of an Identified Use by Dow.

3.  How to check your Product uses

Figure 3: decision diagram for describing uses

Title:
The title already contains a lot of information on what is covered. Dow has strived to develop Exposure Scenarios that are as generic as possible (or in other words cover the majority of activities with a substance within a market sector).

Sector of Use:
Dow will always state the main user group: SU3 (Industrial), SU21 (Consumer), SU22 (Professional). So, for a scenario in industrial setting you will always see SU3. Basically SU3 covers all other SU codes that are related to industrial activities. Therefore, if you have identified your industrial use as SU9 (Manufacture of fine chemicals) or SU11 (Manufacture of rubber products), and you do not find these codes in the Dow description, but only the SU3 code (Industrial), this will mean that Dow covers your industrial use.
Likewise, if you have identified your professional use as SU1 (Agriculture, forestry, fishery)  or SU20 (Health services), and you do not find these codes in the Dow description, but only the code SU22  (Professional), this will mean that Dow covers your professional use.

Process Category: worker uses
The majority of Dow worker Identified Use descriptions (Industrial (SU3) or Professional (SU22)) will contain several PROCs, since generic exposure scenarios aim at covering all activities that are relevant for a specific market sector (e.g. coatings or cleaning agents, metalworking fluids, road&construction materials, etc.). Such use descriptions will contain PROCs that cover the key activities related to the market sector (e.g. for coatings: spraying, brushing, rolling, dipping, pouring). Next to that these uses will state PROCs that cover general activities like (un)loading, transfers, storage, sampling, maintenance, cleaning, waste collection and (for industrial uses) associated laboratory activities. However it is possible that Dow has selected different PROCs for these activities compared to your PROC selection.

When checking whether your worker activities are covered by the PROCs, first check whether the PROCs you have selected are covered by the PROCs in the Dow use description. If some of the PROCs you have selected are not mentioned in the Dow use description, this does not mean that your use is not covered. As explained, Dow may have selected different PROCs for these activities compared to your PROC selection. In this situation we recommend you to look at the description of processes/tasks/activities in Section 1 of the ES (figure 2). Furthermore, you will find descriptions for each type of activity (so-called contributing scenarios covered by the ES) in section 2 of the ES. When these descriptions are in line with your activities with the substance, you can assume that your activities are covered by the Dow Identified Use.

If, after reviewing this information in the ES, the ES contains no textual information that seems to match your use, this still does not mean that your activities are not covered. It is possible that one or more of the PROCs as described by Dow cover the PROCs that you have identified to describe your activities (so called PROC hierarchy; refer to the Cefic guidance for this). In such occasions we recommend you to contact your supplier or visit the supplier’s website to get confirmation on whether your processes/tasks/activities are covered or not.

Process Category: consumer uses
Dow’s consumer uses (SU21) will not contain PROCs! The reason for this is that for the consumer exposure and risk assessment the PROC is not of real significance. Dow will indicate this by ‘n/a’ or ‘not applicable’. For consumer uses, this means that all PROCs are covered by Dow.

Product Category:
The PC will only be indicated for Dow consumer uses (SU21). For consumer uses your selection of PCs has to match Dow’s selection.
Dow’s industrial (SU3) or professional (SU22) uses will not contain PCs! The reason for this is that for industrial or professional exposure and risk assessment the PC is not of real significance. Dow will indicate this by ‘n/a’ or ‘not applicable’. For industrial or professional uses, this means that all PCs are covered by Dow.

Article Category:
The AC is only relevant when there is subsequent service life for a substance. The majority of Dow substances has no further service life after application (end use), so in general Dow will state in the use descriptions that the AC is ‘n/a’ or ‘not applicable’. 

In case of subsequent service life for worker uses: since not the article as such but what you do with it determines exposure, worker exposure (SU3 or SU22) is again determined by the PROCs (for workers). For industrial or professional uses, this means that all ACs are covered by Dow. Dow will indicate this by ‘n/a’ or ‘not applicable’.

In case of subsequent service life for consumer uses: the AC might be of some significance for the exposure and risk assessment, although in general the PC is the driving factor. When Dow’s use indicates  ‘n/a’ or ‘not applicable’, this means that the AC is not relevant for exposure and that all ACs are covered by Dow. When Dow’s use states one or more ACs, your ACs should match the Dow ones.

Environmental Release Category:
The Dow use description will state the ERC that best reflects the environmental release conditions for an Identified Use. You do not really need to check whether you have selected the same ERC as Dow. What is important are the use conditions and risk management measures that Dow recommends to control environmental release. These will be provided in the ES.
The only relevant check on the ERC is whether an ‘industrial’ ERC has been used (local release) or a ‘professional/consumer’ ERC has been used (wide dispersive release):

  • industrial uses (SU3) should always be related to one of the following ERCs: ERC 1 – 7, ERC 12
  • consumer (SU21) or professional uses (SU22) should always be related to one of the following ERCs: ERC 8 - 11