REACH 123

Geoff BrooksChief Software ArchitectThe WERCS, Ltd.

• Web-based tool for getting ready for REACH.• Gather information about substances and

preparations used by your company.• Assess your products/substances.• Maintain information about their status under

REACH.• Maintain information about Legal Entities.• Maintain documents related to the substance.• Perform bulk Pre-Registrations

SIMS Details

• Identify products imported or produced in EU.• Define imported and produced volume figures

from inventory system (ERP, Legacy etc…) by Legal Entity and product.

• Capture CAS-level compositions of each product.• Calculate imported or produced quantity of each

substance across all products for each Legal Entity.

• Define ‘REACH Function’ for each substance.

Product Assessment Steps

Exposure Scenarios for Preparations – New!• Requirement – Manufacturer/Importer obliged to pass on

relevant information down the supply chain.• Information passed describes specific conditions of safe use

and handling as well as exposure scenarios (ES) for the preparation.

• Various Industry groups preparing Generic Exposure Scenarios (GESs)

• WERCS is adding ES authoring and management to it’s list of modules.

• Projected release data is Q4 ’08.• But there is no ‘one fits all’ system.

WERCS ES Methodology

• Create a library of ES documents:– GES document sets from multiple

organizations for groups or categories of products.

– Company created ES document sets for specific finished goods.

– Supplier provided ES document sets for raw materials.

• Build an extension to authoring modules that provides user-friendly method for comparing and constructing ESs for products.

• Modify the SDS template so that 0 to n ESs can be linked to an SDS for a product.

• Make sure the linked ESs become a permanent part of the eSDS.

WERCS ES Methodology (2)

WERCS ES Methodology (3)

• Use an EUWizard (DPD) centered approach to performing as much as possible through automation.

• Support ‘Critical Component Analysis’ approach as a secondary process.

• Allow for expert input by editing phrases and/or creating free text.

Process Flow (2)

WERCS Product with composition

Execute EU Wizard

Execute GHS Wizard

Identify ‘Lead Components’

Identify Substance RMMs

Identify Comparable

GESs

Author ESs by ‘compare and

analyze’

Publish eSDS and ESs

Distribute revised documents

Automated

Expertise

Questions/Comments?