Health, Safety and the Environment
Multisol puts safety at the top of its agenda for its own benefit and for the benefit of its customers and suppliers.
No management function has a higher priority than the safety of those affected by Multisol activities and the company prides itself on continued investment, training and risk management to ensure that, in every situation, Multisol has the right expertise and procedures to protect and support all of its stakeholders.
The company operates a zero tolerance policy to unsafe working practices and is committed to promoting and maintaining safe practices in its day-to-day activities. This is achieved through consultation with employees, external bodies, customers and compliance with current legislation.
For all HS&E related enquiries please contact; firstname.lastname@example.org
Health & Safety
Safety, the safe operation of the business and the health and safety of Multisol employees and its stakeholders is of paramount importance.
Multisol ensures that its systems can deliver by being audited against the occupational health and safety management standard BS OHSAS 18001. The company is committed to maintain and improve safe working practices, both for Multisol employees, its customers and for those involved throughout the supply chain.
The accreditation fits in with Multisol's integrated management system - the OHSAS specification was specifically designed to be compatible with the quality management standard, ISO 9001, and the standard for environmental management systems, ISO 14001.
Environmental Management Systems
Multisol’s Environmental Management System has been accredited to ISO 14001 since 2000.
Through this standard, Multisol is able to identify and manage any environmental impact of its business activities. The company strives for ongoing improvement and its achievements include waste reduction, increased recycling, and focusing on the development of alternative products.
Multisol has been a member of the Chemical Business Association’s (CBA – formerly the BCDTA) Responsible Care Programme since its inception in 1993.
Multisol’s commitment to Responsible Care’s eight Guiding Principles is ongoing as well as to its sustainable development and continuous improvements in health, safety and environmental management.
Multisol assesses its performance against these Principles on a regular basis. Every year reporting on its performance to the CBA. This data is aggregated and published as the chemical distribution industry’s Indices of Performance. Every year Multisol prepares a rolling Improvement Plan to drive improvements in health, safety and environmental management.
The company continues to drive for operational excellence and improvement; this has been recognised by receiving the CBA's Responsible Care Award on three occasions
EUROPEAN SINGLE ASSESSMENT DOCUMENT (ESAD)
Multisol has played a key role in the development of the European Single Assessment Document (ESAD), the pan-European voluntary assessment scheme for distributors. The company piloted the second version of ESAD in 2004, having been part of the original trial.
ESAD avoids the need for distributors to undergo multiple assessments by chemical producers and can also be used by chemical distributors to check their compliance with Responsible Care; as a result, Multisol is permitted to use the Third Party Verified mark for its Responsible Care programme.
ESAD takes the form of a questionnaire used by independent assessors and the assessments take place every three years.
Important REACH deadlines
|June 1, 2007||Reach came into force|
|June 1 - Dec. 1, 2008||Pre-registration|
|Jan 1, 2009||Publication of pre-registered substances by ECHA|
|Dec. 1, 2010||Registration deadline for substances ≥ 1.000 t pa, R5o/R53 substances ≥ 100 t pa, CMR substances of categories 1&2 ≥ 1 t pa|
|June 1, 2013||Registration deadline for substances ≥ 100 t pa|
|June 1, 2018||Registration deadline for substances ≥ 1 t pa|
REACH is the EU chemicals legislation dealing with the Registration, Evaluation, Authorization and Restriction of Chemicals which entered into force on 1st June 2007. REACH covers chemical substances as such, in preparations or in articles (if the substance is intended to be released in normal use). The regulation replaces numerous EU laws and is complementary to other environmental and safety legislation.
What are the objectives?
- Ensure a high level of protection from exposure to chemicals in order to safeguard human health and the environment
- Provide improved risk management
- Stimulate innovation and competitiveness of the EU chemicals industry
- Shift responsibilities from authorities to industry
Which substances are subject to registration?
All substances which are manufactured in or imported into the EU in a quantity above 1 ton per year will have to be registered according to specific deadlines. However there are exemptions from certain parts of the legislation, for example, chemicals used as ingredients in food, foodstuff additives and medicinal products do not need a REACH registration since their safe use is covered by other EU laws.
Who is affected?
- Virtually everyone in the supply chain dealing with chemical substances will have certain obligations.
- Manufacturers or importers of chemical substances or mixtures of chemical substances located in the EU (our suppliers)
- Downstream users processing chemicals, formulating preparations (mixtures) for end-use or using formulated products as part of their business (our customers)
What are the consequences?
‘No Registration – No Market’ meaning that non-registered substances and non-registered uses will become illegal!
Multisol and its parent company Brenntag as full-line distributor covers various roles in the chemical supply chain and therefore is involved by REACH within several aspects. As a distributor in the sense of REACH the company must fulfil its obligations with regards to communication; as a formulator, Multisol is a Downstream User and has to comply with the obligations under REACH (make sure own uses are covered in registration, apply recommended risk management measures) and finally as a manufacturer and a direct Importer of substances it therefore has to fulfil obligations as a registrant.
To appropriately cover these tasks requires REACH involvement on all operational levels (HSE, Sales and Procurement) and a strong internal interaction and alignment. Multisol looks at REACH as an opportunity to serve own customers and suppliers. It has been involved in REACH since the white paper proposal in 2003.
REACH-trained sales team and product managers in every country
- Central REACH implementation team sponsored by top management
- Experienced network of highly skilled HSE experts and state-of-the-art central HSE database
- Active participation and standing contacts to stakeholder organizations (FECC, Cefic, Directors Contact Group)
- Longstanding experience with regards to the handling of chemicals as the link between manufacturers and downstream users
Service to our customers
- REACH-trained sales team supports you in all REACH aspects
- Ensure REACH compliant supply
- Assistance in understanding Exposure Scenarios
- Ensure communication in supply chain
- Assistance regarding imported substances
Service to our suppliers
- REACH-trained product managers support you in all REACH aspects
- Assistance regarding downstream uses
- Ensure communication in supply chain
- Assistance regarding imported substances for Non-EU suppliers
REACH is based on the principle that it is the obligation of the industry to ensure that the substances they manufacture, place on the market or use do not adversely affect human health and the environment.
The Chemical Safety Assessment (CSA) identifies and describes the conditions under which the manufacturing and use of a substance can be regarded to be safe. A CSA has to be carried out if the substance is subject to registration under REACH and manufactured or imported at quantities of 10 tons or more per year.
If as a result of the CSA the substance meets criteria that classifies it as dangerous or as PBT (persistent, bioaccumulative and toxic) or vPvB (very persistent and very bioaccumulative), then an exposure assessment will be needed.
The final result of the exposure assessment is the Exposure Scenario (ES) which is the set of information that describe the conditions under which the risks associated with the manufacturing and the identified uses of a substance can be controlled. The ES defines the operational conditions and risk management measures that need to be applied to ensure the safe use of the substance during all life stages. The ES is communicated as an attachment to the Safety Data Sheet (SDS). Together the SDS and the ES form a new document, the “extended SDS” (extSDS), which is the legal REACH document communicated down the supply chain. There is no standard format for the ES.
Obligations for Downstream Users
As a Downstream User you will receive an ES attached to the SDS (extSDS) when the substance that has been registered is classified as dangerous, PBT or vPvB. If you purchase a preparation that contains such substance(s) the SDS will also be extended by Exposure Scenario(s) per respective substance (depending on the registration deadline of the substance).
If you receive an SDS with an Exposure Scenario, it is your obligation and responsibility to check and to ensure that your conditions of use are covered by that Exposure Scenario and to apply the recommended risk management measures. This means that, in a first step, you have to compare the conditions described in the Exposure Scenario with your own practices. There are three possible outcomes:
- Your use is covered – no further action to take
- Your use differs from the ES – more detailed compliance check is needed
- Your use is not covered by ES – you have to take action by choosing among 4 options:
- Change your conditions of use in order to be compliant
- Inform suppliers about the missing use / conditions of use
- Select alternative supplier which has covered missing use / conditions of use in his registration
- Special uses / conditions of use for which no registrant can be found may need a Downstream User Chemical Safety Report. If you decide to do so, you have to inform ECHA within 6 months after receipt of the extSDS that you will carry out an assessment yourself.
Exemption: If you use less than 1 ton per year you do not have to do a CSR, but you need to notify ECHA at the latest 6 months after receipt of the extSDS.
If any of your uses / conditions of use appears not to be covered in the extSDS you have a certain time to make the missing use REACH compliant. According to Article 39-1 you may continue to apply this use / conditions of use during a 12-month period which starts at the date you receive the registration number communicated via the extSDS.
Reasons for not receiving an ES:
There might be several reasons for not receiving an ES:
- The substance is exempt
- The substance is manufactured/imported in volumes less than 10t/y
- The substance is not classified as dangerous (non-hazardous substance)
- The substance is due to be registered at later deadline
Safe Use for all Identified Uses
The REACH regulation sets a number of new requirements with respect to the use of chemical substances and the associated communication between suppliers and customers. One of the new requirements is the demonstration of “safe use”. This implies that all actual uses of all substances that need registration must be identified by or reported to the registrant (Manufacturer/Importer). This is done during the Use Alignment Process. After this process the registrant has to investigate whether the identified uses can be considered as safe. This analysis is made in the Chemical Safety Assessment.
In the Chemical Safety Assessment the Manufacturer/Importer has to demonstrate safe use of the substance throughout the whole lifecycle (manufacture, formulation, end-use, waste). The outcome of the assessment is a set of Operational Conditions and Risk Management Measures which help to achieve safe use. This information is laid down in the Exposure Scenario, which will be communicated after the registration via the extended Safety Data Sheet (extSDS). It will be the legal duty of Downstream Users to follow the instructions stipulated in the Exposure Scenario.
Exposure and Safe Use
The “use” of a chemical substance conceived by REACH as any activity (e.g. processing, formulation, mixing, filling, and production of an article) which is carried out with a substance as such or in a preparation could lead to some form of “exposure” of humans or the environment. Exposure infers some form of contact of humans and/or the environment with chemical substances whereas the contact can occur short term, long term, once or more often, in low or high concentrations.
For industrial safety and for protection of humans (workers and consumers) and the environment, the way, the duration and the concentration at which substances with hazardous characteristics are applied is crucial. In this context “safe use” means that the Downstream User can demonstrate that exposures are so small or not existent that no harmful effects to humans and the environment are to be expected to occur.
The “safe use of chemicals” is the fundamental aim of the REACH Regulation. One important step to achieve safe use is to assess all potential exposures. Manufacturers and Importers as well as their customers in the role of Downstream Users have their obligation in this regard. Safe use is dependent on several preconditions: good knowledge of substance properties, of conditions of use, of any exposure as well as the development and implementation of appropriate risk management measures to adequately control the risks. While the Chemical Safety Assessment (CSA) evaluates whether the intended uses of a substance are “safe”, it is the Exposure Scenario (ES) that describes the conditions for safe use of a substance, in particular the conditions of safe use and the risk management measures.
To structure the large number of different uses of substances and preparations present in the different industry sectors ECHA has developed a system to describe uses in a standard and structured way. This so called “Use Descriptor System” is based on five separate categories. Each category has pre-defined descriptors which in combination with each other form a brief description of use. The five categories are: sector of use (SU), chemical product category (PC), process category (PROC), article category (AC) and environmental release category (ERC).
Sector of Use [SU]
In a supply chain a chemical substance passes different industry and trade sectors before it reaches its final destination. Under REACH each sector represents an identified use. Often the life cycle includes one or more formulation stages in the chemical industry, and one or more distribution stages in the trade sector. ECHA determined five main user groups which play a role along the life cycle of a substance: manufacturers of chemical substances (i.e. transforming substances into other substances) [SU8/9], companies (formulators) that mix and blend chemicals (without transforming into other substance) [SU10], industrial end-users that use the chemical in their manufacturing processes [SU3], professional end-users [SU22] and private households [SU21] that apply substances or preparations.
Chemical Product Category [PC]
The Chemical Product Category characterizes the use of a substance by the type of end-use preparation (e.g. lubricant, cleaner, adhesive) in which the substance is known to be used. This is based on the consideration that the use of a preparation is closely related to exposure potential.
Process Category [PROC]
Process category groups the way a substance is used or converted into a subsequent product (preparation or article). Application techniques or process types have a direct impact on the exposure to be expected and hence on the risk management measures needed.
Article Categories [AC]
For dangerous substances processed into articles, the manufacturer or importer of the substance may find it necessary to specify which types of articles are covered in the CSA and the ESs. It will, for example, make a difference in terms of exposure whether a substance is used in textile-finishing of clothes (dermal contact, frequent washing) or as a component in insulation sheets for construction purposes.
Environmental Release Categories [ERC]
Release estimation is the process whereby releases to the environment are quantified during the life cycle stages of a chemical, taking into account the different types of uses during these life cycle stages, the different emission pathways and receiving environmental compartments and the spatial scale of the emissions. To streamline the release estimation and make it accessible for data collection in the supply chain, environmental release categories (ERCs) have been developed. ERCs label the characteristics of a use based on different aspects relevant from environmental perspective.
What are my obligations as a customer of Multisol/Brenntag under REACH?
As a customer your are, in terms of REACH, a Downstream User and as such you should follow the risk management advice and the operational conditions of use described in the extended safety data sheet (extSDS) received from the supplier. If applicable, forward the advice to actors further down the supply chain. If you as a Downstream User produce a preparation (you are a formulator), you must ensure that the extSDS for that preparation includes all relevant information received from the suppliers of the individual components. Please note: This was already a duty of downstream users under previous legislation. The new element under REACH is the receiving and forwarding of use-specific risk management advice and risk management measures relating to exposure to humans or the environment.
Under what conditions do I receive an extSDS?
A SDS extended by an Exposure Scenario is obligatory when the substance is classified dangerous and manufactured at a quantity of 10 tons or more or is assessed to be a PBT or vPvB. Depending on the registration deadline according to the manufacturer’s production volume of the dangerous substance the extSDS will be provided a few months after the respective registration deadline. If a substance is exempt, not classified as dangerous or produced at a volume below 10 tons, an extSDS will not be provided.
What – in a few words - is an Exposure Scenario?
The Exposure Scenario documents the result of the exposure assessment and risk characterization and describes under what conditions the chemical substance is manufactured or used safely in the areas of environment, workplace and consumer during its life-cycle. The Exposure Scenario shall address all identified uses. The Exposure Scenario is attached to the SDS as an extension. Please see also section Exposure Scenarios in this website.
What will be the format of extSDS?
The format of the so called body is regulated in Annex II of the Regulation “Guide to the Compilation of Safety Data Sheets”. Multisol and Brenntag will of course follow the regulation. Unfortunately no official format for shape and format of the Exposure Scenario has been developed. The Guidance from May 2008 “Guidance on information requirements and chemical safety assessment – Part D: Exposure Scenario Building” suggests a 9-chapter format. In the meantime, both Industry and ECHA are working with a 4-chapter format. Additionally there is currently no standard for electronic communication of extSDS.
Will my uses be supported in the registration dossier?
We have communicated the information about uses which we received from our customers to our respective suppliers in accordance with Article 37. We believe that most of the common uses which have been identified by the various industry associations will be covered in the registration dossiers. Since Multisol and Brenntag for the vast majority of its product portfolio will not register any of the substances the companies are not in the position to make any statements on which uses will or will not be included in the respective dossiers submit by our suppliers. The supported uses and conditions of use will be communicated via the SDS extended by Exposure Scenarios, the so called extended SDS (extSDS). Downstream Users are well advised to check their uses and conditions of use related to the substance soon upon receipt of the extSDS. Please note: if the substance is non-hazardous no Exposure Scenario is required and, apart from consideration of work-safety obligations, no further action for the Downstream User is necessary. For further information please see also section Exposure Scenarios in this website.
What is meant by “conditions of use”?
Conditions of use are determined on one hand by the physical properties of the substance on the other hand it is the frequency and duration of use, applied risk management measures and operational conditions that determine the conditions of use.
What if any of my uses is not covered in the registration dossier?
If any of your uses / conditions of use appears not to be covered in the extSDS you have 12 months to make the missing use REACH compliant. According to Article 39-1 you may continue to apply this use / conditions of use during a 12 month period which starts at the date you receive the registration number communicated via the extSDS. For further information please see also section Exposure Scenarios.
What options do I have, if my use is not covered?
During the 12 months following receipt of extSDS you may choose among several options to make your operations REACH compliant:
- Change conditions of use in order to be compliant
- Contact your supplier and inform them about the missing use / conditions of use
- Select an alternative supplier which has covered the missing use / conditions of use in his registration
- Special uses / conditions of use for which no registrant can be found may have to be assessed and reported to ECHA by the Downstream User himself (Articles 37-4, 38-1 and 39-2)
For further information please see also section Exposure Scenarios.
Within this context we recommend also to refer to our customer information or to the document “Downstream users: are your uses covered?” provided by the European industry association for small and medium sized companies (UEAPME).
Can I continue to use substances supplied before registration deadline and that are not registered?
Pre-registered substances that are manufactured or imported before the relevant registration deadline can still be used and placed on the market after this date by any downstream user, distributor or supplier in the supply chain even if the manufacturer did not submit a registration. If you are a Manufacturer or an Importer of that substance you must have ceased such activities before the relevant deadline to benefit from this rule. However any actor down the supply chain who is not subject to the registration obligation may continue to use and/or supply quantities of the substance that were supplied to them before the registration deadline.