Group III Ways to Establish Good Communication in the Chain „Manufacturer, importer, Downstream User – Competent Authority“ Seminar on Chemical Substance Self-Classification Issues in the Context of Seveso Directive Vilnius, 23 October 2013

Problems identified 1.Limited knowledge regarding the classification of hazardous substances SDS not always provided to the Seveso CA at the time of notification Reliability of the information of the SDS and lack of information SDS not always complete Seveso CAs have to check the SDS though they are not experts in that matter and don’t have the resources. Users don’t always have the information on the suppliers. 2.Identification of the chain of responsibilities Difficult to separate CL& REACH responsibilities from Seveso responsibilities 3.Incomplete tools C and L inventory does not apply to mixtures 4.Limited communication Between CLP and Seveso inspection units. Identification of the SDS to take into consideration for Seveso. At a political level, between the services of the Commission and between the Comission and the MS. Between suppliers and users.

2.Improvement of the reliability of the SDS Proposed solutions 1.Better cooperation between Seveso CA/inspectors and relevant CLP experts Working groups between different inspection units to compare the SDS in PL Exchange on the notifications received between CLP and Seveso experts in LT Joint CLP and Seveso inspections in FI Improvement of knowledge on CLP and Seveso by respectively Seveso and CLP authorities 2.Improvement of the reliability of the SDS Joint notifications and registrations to consider in priority . Cross checking of SDS with national databases in LT, PL, FR and interconnections with other existing databases, at the EU level and in other MS. Update of databases. Discussion forum in NL. Industrial safety advisory body in HU. Forum for REACH enforcement in PL.

3. A better identification of the chain of responsibilities Proposed solutions 3. A better identification of the chain of responsibilities Incentives for the operator and downstream users to have a correct classification and to complete all the sections of SDS . Correct information linked to the permit in France. Possibility to put a condition to a supplier for good information. Coordination by the Commission to solve CLP and Seveso problems at the European level with article 4 and revision of annex I Raising awareness about the responsibilities involved with the obligation of information. Ex > audits, trainings. Raising awareness on the pros and cons of compliance and non compliance

Proposed solutions 4. Improvement of communication between suppliers, between operators and CA, between the CAs, etc Small groups of discussions between suppliers and users in NL. Exchange of information at the industrial level, in sectoral associations. Common templates for notification demonstrating the degree of details needed. Example of electronical templates in IE. IF too many divergences, possibility to go to ECHA for advice. On case by case basis, possibility for the CA to look for the good information in the SDS.