1. Nalco Europe B.V. REACH Together Huw P. Jones REACH Program Manager 26 th August 2007 Meeting the challenge ~ Our strategy Organize Invest REACH along the Chain

2. REACH Threats German VNCI estimate billions of Euros of cost will enter the supply chain in coming years CEFIC estimate 10–30% of substances may disappear Increased regulatory burden - Dossiers will stay open and will need tracking and developing Will be harder to sell certain chemistries e.g. CMRs Increased cost, regulatory and reformulation may force smaller companies to close

3. ScopeScope HS OH HS OH Benzene Preparation/MixtureSubstance Applies to the substance, not the mixture = 3 registrations Octanol Mercapto-ethanol Nalco ABC OH

4. RegistrationRegistration Working in partnership, companies MUST provide :- Working in partnership, companies MUST provide :- - Dossier of physio-chemical and toxicological information –Chemical Safety Report to cover each use and fate The bigger the volume, the more data is required The bigger the volume, the more data is required Thresholds are: Thresholds are: –Tonnage per year: 1,000 - 100 - 10 - 1 –Very high concern: Carcinogens, mutagens, reproductive toxins & endocrine disruptors & persistent, bio-accumulative & toxic chemicals Phased over 11 years with high tonnage / high concern considered first Phased over 11 years with high tonnage / high concern considered first

5. Registration time-line 01-06 2013 01-06 2010 01-06 2018 01-12 2008 >1000 T.Yr >1 T.Yr CMR >100 T.Yr PBT/vPvB Pre-registration Agency start up 100 – 1000 T.Yr 10 -100 T.Yr 01-06 2008 01-06 2007 Chemical Safety Report Dossier x 1 -10 T.Yr Nalco is on track to meet its registration obligations

6. REACH Program REACH MARKETING LEGAL SH&E INFORMATION SYSTEMS RESEARCHSALES MANUFACTURING PROCUREMENT Nalco recognizes that REACH is business critical to Nalco & our customers

7. Organize for REACH “Deliver REACH compliance in a timely and cost effective manner whilst supporting our customer’s needs” Steer REACH David Johnson Deborah Hockman VPs Operations & SHE Inventory 4 REACH Jim Ferguson Toxicology 4 REACH Ricky Stackhouse Cosmo CASE STUDY Huw P. Jones Supply Chain (SC) REACH Nelma Tavares Communicate REACH Lian Van Baal Work REACH Huw P. Jones Chair by VP Europe BU General managers Marketing managers Research Director Finance Director Procurement director Legal counsel Manufacturing director Nalco fully supports REACH & has the people & programs to meet this new regime

8. Program segments Programme breaks down into a number of segments Programme breaks down into a number of segments Nalco will in many cases sits at supply chain inter-face Nalco will in many cases sits at supply chain inter-face

9. Current inventories generated manually Current inventories generated manually Nalco’s planned investments include an automated SAP solution Nalco’s planned investments include an automated SAP solution And adoption of ICUCLID 5.0 software for registration dossiers And adoption of ICUCLID 5.0 software for registration dossiers Investing in REACH

10. REACH along the chain Established reach@nalco.com Strategy Supplier focus Supplier focus Customer focus Customer focus Hear Nalco Hear Nalco Effective communication is key Effective communication is key Suppliers Customers Procurement Management teams manufacturing Sales & Marketing SH&E Research & Development Hear

11. Customer focus General customer enquiry letter General customer enquiry letter SDS REACH Statement SDS REACH Statement Integrate clear REACH guidance into Nalco Direct web offerings Integrate clear REACH guidance into Nalco Direct web offerings reach@nalco.com established reach@nalco.com established reach@nalco.com Customer seminars Face to face presentation for key accounts Face to face presentation for key accounts Bulletin available with core messages Bulletin available with core messages Webex seminars As above for other customers but run as Webex conference As above for other customers but run as Webex conference Sales Briefing Q&A Customer Brochure Secured supply ~ the process link

12. Supply Chain REACH - Safety Data Sheets Requirements Email address of the person responsible for the SDS Email address of the person responsible for the SDS Sequence of chapter 2 and 3 is reversed Sequence of chapter 2 and 3 is reversed Gradually over time all SDSs will be extended with exposure scenarios for intended uses Gradually over time all SDSs will be extended with exposure scenarios for intended uses How is Nalco going to implement and be legally compliant? New lay out is ready and will be implemented per 1-6-2007 New lay out is ready and will be implemented per 1-6-2007 Will change to new SDS for each new product/SDS or after significant change Will change to new SDS for each new product/SDS or after significant change Gradually over time all SDSs will change to new lay out (deadline 1-12-2010) Gradually over time all SDSs will change to new lay out (deadline 1-12-2010)

13. Supplier focus - REACH UP Open communication lines Open communication lines Integrate REACH messages into Nalco Direct web offering Integrate REACH messages into Nalco Direct web offering Briefing bulletin on Nalco’s expectations Briefing bulletin on Nalco’s expectations reach@nalco.com established reach@nalco.com established reach@nalco.com REACH integrated into supplier contracts REACH integrated into supplier contracts REACH integrated into toller contracts REACH integrated into toller contracts Establish database to capture supplier responses Establish database to capture supplier responses Establish SAP capability to hold and use supplier responses including REACH contacts, use & fate and registration response Establish SAP capability to hold and use supplier responses including REACH contacts, use & fate and registration response

14. Supplier focus - Secured Supply Confirm in writing that each chemical you supply will be pre-registered Highlight any chemicals, which in your view will meet the definition of carcinogen, mutagen or reproductive toxin (CMR) category 1 & 2 or the persistent, bio-accumulative and toxic (PBT/vPvB) definitions Highlight if your supply of any chemical is likely to exceed 1,000 tonnes per year Highlight any chemical(s) for which Nalco and its groups companies account for a significant proportion (nominally more than 25%) of your total EU sales volume Provide contact details of the person or person(s) responsible for the day-to-day running of your REACH program and to whom questions & information should be directed

15. Supplier focus - 2 Steps, 3 Waves Chase Top 100 Suppliers - 80% spend Tollers and Non EU Suppliers Low volume Suppliers Use & Fate communication Wave 1 Wave 2 Wave 3 Step 1 Step 2 Open lines

16. Supplier focus - Responses Feedback so far Many have no defined contact centre Many have no defined contact centre Few will commit to register although many will now pre-register Few will commit to register although many will now pre-register Supply chain complex with multiple suppliers Supply chain complex with multiple suppliers Some initially give only general responses Some initially give only general responses Too early to exchange use & fate information as no EU Guidance Too early to exchange use & fate information as no EU Guidance Nalco will pre-register all our chemicals and also no response chemicals & switch suppliers

17. Downstream Users Use & Fate To be developed: We will identify the use and fate of our products via Nalco Marketing and R&D We will identify the use and fate of our products via Nalco Marketing and R&D We will verify the outcome with our customers We will verify the outcome with our customers Downstream use: to be developed Scheduled beginning 2008

18. Exposure Patterns Closed System Accidental Soil Waste Air Continuous Matrix Inclusion Occasional ConsumerProfessionalIndustrial Non- Dispersive Dispersive Water OralInhalationDermal Human Environment

19. + Use Category ? Industry Category Use Category

20. Registration of 1,000 T.Yr chemicals Registration of 100 T.Yr chemicals Registration of 1 T.Yr chemicals 201020132018 2008 2009 Brief internal teams on program Make an inventory of all Nalco chemicals Develop SAP Inventory tool REACH ALONG THE CHAIN - Supplier communication Draft customer communication material including web offering Review & organize all existing toxicity data Commence work on analytical substance support Develop budget forecast & make strategic support hires Modify MSDS template Identify use & fate information for all chemicals Communication use & fate to suppliers & customers Complete key account briefings Pre-register all Nalco chemicals Initiate tox testing on all New & 1,000 T.Yr chemicals Establish consortia for high volume chemicals Complete toxicity testing on all 1,000 T.Yr chemicals Draft CSA/CSRs and dossiers for 1,000 T.Yr chemicals Data exchange & SIEF formation target 100 T.Yr chemicals Identify non-supported supplier chemistry & uses Develop & Initiate reformulation strategy Pre-register Nalco chemicals REACH Ahead