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REACH Downstream User Obligations Audit Checklist

A comprehensive audit checklist for downstream users of chemicals to ensure compliance with their specific obligations under the REACH regulation, focusing on communication, safety measures, and reporting requirements.

REACH Downstream User Obligations Audit Checklist

by: audit-now
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About This Checklist

The REACH Downstream User Obligations Audit Checklist is a vital tool for companies that use chemicals in their industrial or professional activities within the European Union. This checklist addresses the specific responsibilities of downstream users under the REACH regulation, ensuring compliance with communication, safety, and reporting requirements. By systematically reviewing downstream user obligations, businesses can improve chemical management practices, enhance workplace safety, and maintain regulatory compliance throughout their supply chain.

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Industry

Chemicals

Standard

REACH - Registration, Evaluation, Authorization of Chemicals

Workspaces

laboratories
Industrial Sites
Manufacturing Facilities
Industrial Plants

Occupations

Environmental Health and Safety Manager
Regulatory Compliance Officer
Chemical Process Engineer
Supply Chain Manager
Product Stewardship Specialist
1
Is the downstream user in compliance with REACH regulations?
2
Is there adequate chemical safety documentation available?
3
What is the risk level associated with the exposure scenarios?
Min: 1
Target: Moderate Risk
Max: 10
4
Is there effective communication regarding chemical risks in the supply chain?
5
Are risk management measures in place for chemical use?
6
Is there a comprehensive inventory record of chemicals used?
7
Are Safety Data Sheets (SDS) available for all chemicals in use?
8
What percentage of employees have received training on chemical safety?
Min: 0
Target: 100
Max: 100
9
Has a comprehensive risk assessment been completed for all chemicals?
10
Is there a mechanism in place for reporting chemical incidents?
11
Are exposure scenarios compliant with REACH requirements?
12
What is the total quantity of chemicals used in the facility (in kg)?
Min: 0
Target: 1000
Max: 10000
13
Is there an emergency response plan in place for chemical spills?
14
Are all chemicals properly labeled according to REACH requirements?
15
Describe the practices for communicating chemical safety information with suppliers.
16
Are all chemicals registered with the relevant authorities as per REACH?
17
What is the total volume of high-risk chemicals used (in kg)?
Min: 0
Target: 500
Max: 5000
18
Are regular compliance audits conducted for chemical use?
19
Describe the chemical safety training programs offered to employees.
20
Is there a process to verify supplier compliance with REACH?
21
Are risk assessments updated regularly to reflect current practices?
22
What procedures are in place for reporting chemical-related incidents?
23
What percentage of chemical waste is disposed of in compliance with regulations?
Min: 0
Target: 100
Max: 100
24
Describe the health and safety policies regarding chemical use in the workplace.
25
Is emergency equipment for chemical spills readily available?

FAQs

Downstream users are responsible for implementing risk management measures communicated in Safety Data Sheets, checking if their uses are covered by their suppliers' exposure scenarios, communicating uses up the supply chain, and potentially preparing chemical safety reports for uses outside the conditions described by suppliers.

The checklist includes items to verify that downstream users are effectively communicating their uses of substances to suppliers, reporting relevant information up the supply chain, and properly conveying safety information to their own customers.

The checklist guides users through the options available in this situation, including contacting the supplier to have the use included in their chemical safety assessment, changing the conditions of use to comply with the exposure scenario, finding an alternative supplier, or conducting their own chemical safety assessment.

It includes steps to verify that the downstream user has compared their actual conditions of use with the exposure scenarios received from suppliers, and has documented this comparison as part of their REACH compliance efforts.

The checklist helps ensure that downstream users maintain appropriate records of their REACH-related activities, including received Safety Data Sheets, communication with suppliers, internal use assessments, and any chemical safety reports prepared, for a minimum of 10 years as required by the regulation.

Benefits of REACH Downstream User Obligations Audit Checklist

Ensures comprehensive understanding and fulfillment of downstream user obligations under REACH

Helps identify and address gaps in chemical safety information and risk management measures

Improves communication and collaboration with suppliers and customers in the chemical supply chain

Reduces the risk of non-compliance and potential disruptions to business operations

Supports the development of safer and more sustainable chemical use practices