ECHA initiative to improve the quality of the information on use and conditions of use communicated up the supply chain and the efficiency of this communication process, referred to as ECHA USe Maps.
In the initial phase of REACH, when the first MDI, TDI and NLP Polyols dossiers were submitted in 2010, the manufacturers/importers of those substances have been developing exposure scenarios, together with input from downstream, describing where a substance is used, under which operational conditions and with what type of typical risk reduction measures.
The MDI Consortium welcomes the initiative of ECHA to stimulate downstream users to revisit their uses and use conditions to improve completeness and quality, but also recognize that this could cause alignment issues (even potentially non-compliance) with current existing exposure scenarios described in the REACH dossiers of the manufacturers/importers of MDI and TDI and polyols and hence eSDS’.
Hence, the MDI Consortium finds it important to involve it when you decide to review the uses and use conditions of MDI and TDI to ensure we remain aligned and that the communication to the MDI, TDI and NLP Polyols users will be uniform, harmonized and clear from both the manufacturer and the downstream associations.
More information on the ECHA Use maps is available here (https://echa.europa.eu/csr-es-roadmap/use-maps/concept).
Do not hesitate to contact REACH Centrum as soon as possible in case you have started already with the use maps or are planning to do so. The relevant consortium will contact you to discuss a joint approach that will be beneficial for all stakeholders.