Waste requirements under REACH
ECHA released a new guidance document on the waste life stage under REACH in December 2010 titled: “Exposure scenario building and environmental release estimation for the waste life stage.”
This obliges manufacturers and importers to:
- Provide general information in the technical dossier on types, amounts and composition of waste occurring on the manufacture and use of the substance,
- Take the waste life cycle stage into account when undertaking the appropriate exposure and risk assessments embedded in the exposure scenario for their identified uses,
- Communicate RMM required to control risk of waste down the supply chain via the eSDS.
As of 2011, the level of detail provided in the REACH dossier on the waste was limited but due to the new guidance this should be updated and extended. A questionnaire has been drafted which aims to compile information on the amount of waste generated at each site and to determine the waste management measures or treatment techniques (internal and/or external waste management) in place. Please fill out the questionnaire for your use or manufacturing process and return it to the Nickel Reach Consortia.
This information will be used for the next update to the Ni REACH dossiers and in particular the generic exposure scenarios for the different manufacturing processes and uses currently in the REACH registration dossiers.
Please ensure the questionnaire is completed and returned by email to Keegan Hicks and Marnix Vangheluwe by September 1st, 2011
