REACH Downstream User Obligations Audit Checklist

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.