With the implementation of REACH in full swing, the first major milestone, pre-registration, has been passed already and the second, registration of large volume substances, is coming up. Bayer MaterialScience is acting to ensure the further availability of its products through appropriate action in the registration process. Through on-going communication with downstream users, industrial associations and suppliers regarding uses of substances that are part of our products, we are making every effort to keep all its customers informed about the latest developments.
The registration process for substances manufactured or imported in volumes exceeding 1,000 t p.a. is under way. As far as applicable, we have taken the use proposals compiled by important industry associations such as CEPE, FEICA and ISOPA to assign possible REACH uses to the products we sell. Through this approach we assume that we have mainly covered the typical processing methods and exposures. However, we will not be supporting all the proposed uses from the relevant industry associations and hope you understand that, at present, we cannot make any formal statements about future uses being covered.
Furthermore, ISOPA has defined its supported uses through the Use Descriptor System recommended by the updated ECHA guideline for isocyanates and polyols, and provided constructive user guidelines regarding use of the respective descriptors. These guidelines were discussed and aligned with the other industry organizations mentioned above. We support this approach, though with a much broader scope, i.e. applying to all isocyanates and substances containing isocyanate groups and all polyols, amines or other conceivable reactants of said isocyanates and substances containing isocyanates.
Since we will not consider any descriptors listed as nonapplicable in the ISOPA documents, they will not be part of our future REACH-related investigations. At present, we are not in a position to forecast any limitations in uses that may result from risk assessments or limitations detailed by our suppliers. Having already made a start with the issue of the first eSDS, we will be communicating such information from mid-2011 on a broader basis through eSDS so that our customers will be able to check whether their uses are covered.
