Exposure Scenarios for REACH
The Downstream Users of Chemicals Co-ordination Group (DUCC) is a platform of European associations which represent “downstream” industries. It has developed a common format for reporting uses under REACH. Many sectors of industry have used this format to provide a tool to DU Associations (and their members) for mapping and reporting uses for their respective sectors. Uses should be mapped using the Use Descriptor System. Additional information is provided to allow exposure assessment at screening level (using ECETOC TRA). Each Downstream User Association is responsible for filling and updating the use information for its sector, following the format provided in this document. DU Associations are advised to make their lists of uses publicly available and/or accessible to Manufacturers/Importers as relevant.
Until recently the oil and gas industry had no specific format for mapping uses for the sector. EOSCA is promoting a common format for the sector by offering one developed for its members and any others in the industry. This can be viewed and downloaded for use here.
Compliance with REACH in the Dutch Sector
The regulation of chemicals used offshore since 2001 has been by legislation derived from the OSPAR Harmonised Mandatory Control Scheme (HMCS) incorporated into National Legislation by the various Contracting Parties to OSPAR. The HMCS Decision was revised to require that chemical usage was compliant with the REACH Regulations relevant to any substances in the formulations used offshore. To this end The Netherlands are about to introduce a REACH compliance check on all chemicals used offshore. This will require Operators to complete forms with information on any hazardous components of formulated products and to submit these to the Dutch Regulatory Authority. Some of the information required on the form is not normally available to the Operator and as such requires chemical suppliers to complete part of the form. A trial period is due to start on 1 January 2013. The forms to be completed have been developed by the Dutch regulator in co-operation with EOSCA and the Dutch Operator Association, NOGEPA.
The forms to be completed and attendant Guidance Notes may be downloaded from the Dutch Regulator website. The Dutch Regulator will also be checking chemicals used for drilling operations onshore with a similar process of forms being completed by Operators. These may also be downloaded from the SodM website.
EGEST – Generic Exposure Scenario Tool for REACH and the Oil and Gas Industry
EGEST allows a first pass screening assessment (Tier 0 & Tier 1) of inhalation and dermal exposure together with environmental discharge assessment for substances with a view to help fulfilling the requirements of the REACH legislation. The EU Legislation for the Registration Evaluation, Authorisation and Restriction of Chemicals, REACH, is the main tool for regulating chemicals manufactured or imported in the EU. As part of the Registration process it is necessary to compile a database of information in IUCLID, and to carry out a Chemical Safety Assessment (CSA) and write a chemical safety report (CSR) for certain substance categories.
The EGEST tool is a Generic Exposure Scenario Tool, designed to be used by chemical suppliers, operators and other chemical users working with exploration and production chemicals in the North Sea. The tool helps to map known offshore uses to use descriptors and environmental release codes. Relevant codes are included in the tool. If more codes are required please advise EOSCA.
The EGEST Excel based tool also helps to perform generic risk assessments for the offshore use of oilfield chemicals. It does not cover earlier phases in the life cycle such as manufacture and formulation which should be covered elsewhere.