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.

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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?

Select compliance status.

To assess the level of compliance with REACH requirements.
2
Is there adequate chemical safety documentation available?

Provide details about the documentation.

To ensure that safety documentation is maintained as per regulatory obligations.
3
What is the risk level associated with the exposure scenarios?

Provide a risk level from 1 to 10.

To evaluate the potential risks linked to chemical exposures.
Min1
TargetModerate Risk
Max10
4
Is there effective communication regarding chemical risks in the supply chain?

Select the frequency of communication.

To confirm that information is being adequately shared to mitigate risks.
5
Are risk management measures in place for chemical use?

Indicate if measures are in place.

To verify that appropriate measures are implemented to manage risks.
6
Is there a comprehensive inventory record of chemicals used?

Provide details of the chemical inventory.

To ensure accurate tracking and compliance with REACH registration.
7
Are Safety Data Sheets (SDS) available for all chemicals in use?

Describe the availability of SDS for chemicals.

To confirm that necessary safety information is accessible to all workers.
8
What percentage of employees have received training on chemical safety?

Enter the percentage of trained employees.

To evaluate the effectiveness of training programs related to chemical safety.
Min0
Target100
Max100
9
Has a comprehensive risk assessment been completed for all chemicals?

Select the completion status of risk assessments.

To ensure that potential risks associated with chemicals are identified and managed.
10
Is there a mechanism in place for reporting chemical incidents?

Indicate if an incident reporting mechanism exists.

To ensure that incidents are reported and managed effectively.
11
Are exposure scenarios compliant with REACH requirements?

Select the compliance status of exposure scenarios.

To assess if exposure scenarios align with regulatory standards.
12
What is the total quantity of chemicals used in the facility (in kg)?

Enter the total quantity of chemicals used.

To monitor the volume of chemicals being utilized and ensure compliance.
Min0
Target1000
Max10000
13
Is there an emergency response plan in place for chemical spills?

Indicate if an emergency response plan exists.

To ensure preparedness for chemical-related emergencies.
14
Are all chemicals properly labeled according to REACH requirements?

Provide details on chemical labeling compliance.

To verify that all chemical containers meet labeling regulations.
15
Describe the practices for communicating chemical safety information with suppliers.

Detail the communication practices in place.

To assess the effectiveness of communication regarding chemical risks.
16
Are all chemicals registered with the relevant authorities as per REACH?

Select the registration status of chemicals.

To ensure that all chemicals are compliant with registration requirements.
17
What is the total volume of high-risk chemicals used (in kg)?

Enter the total volume of high-risk chemicals used.

To monitor the use of high-risk chemicals which may require stricter compliance measures.
Min0
Target500
Max5000
18
Are regular compliance audits conducted for chemical use?

Indicate if regular compliance audits are performed.

To verify that the organization conducts audits to ensure ongoing compliance.
19
Describe the chemical safety training programs offered to employees.

Provide details about the training programs.

To assess the adequacy of training related to chemical safety.
20
Is there a process to verify supplier compliance with REACH?

Select the status of the supplier compliance verification process.

To ensure that suppliers are adhering to REACH regulations.
21
Are risk assessments updated regularly to reflect current practices?

Indicate if risk assessments are updated regularly.

To ensure that risk assessments are current and relevant to ongoing operations.
22
What procedures are in place for reporting chemical-related incidents?

Provide details about the incident reporting procedures.

To evaluate the effectiveness of incident reporting procedures.
23
What percentage of chemical waste is disposed of in compliance with regulations?

Enter the percentage of compliant chemical waste disposal.

To assess compliance with disposal regulations for chemical waste.
Min0
Target100
Max100
24
Describe the health and safety policies regarding chemical use in the workplace.

Detail the health and safety policies in place.

To evaluate the comprehensiveness of health and safety policies.
25
Is emergency equipment for chemical spills readily available?

Select the availability status of emergency equipment.

To confirm that necessary emergency equipment is accessible for safe operations.

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

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