The chemical industry is one of the largest production sectors in the EU, but the “success” of the chemical industry can unfortunately become the Achilles’ heel of modern times. The progressing chemization inevitably leads to the devastation of the natural environment and is the cause of many dangerous diseases. A review of the chemical policy conducted by the EU Commission in 1998 showed that the legal regulations in force at that time did not sufficiently protect against the harmful effects of produced and used chemicals. The existing system, being a mosaic of many directives and ordinances, distinguished chemicals registered in September 1981 (“existing substances”) and introduced on the market since then (“new substances”).
In 2007, Regulation 1907/2006, commonly referred to as REACH, was introduced, which completely changed the paradigm in the approach to managing chemical safety. The scope of the REACH Regulation covers processes, such as Registration, Evaluation, Authorization and restriction on Chemicals. The most important and fundamental novelty was the transfer of the burden of responsibility for chemical safety from Member States to companies. Under the REACH Regulation, small and medium-sized enterprises (SMSs), that cannot afford to hire a specialist in the field of chemical safety management (CSM), have the same tasks as large companies and cannot be exempted from any chemical safety obligations.
Two years after implementation of the REACH Regulation, came into force next complex regulation, Regulation No 1272/2008, so-called CLP Regulation. The provisions of REACH and CLP complement each other. The REACH Regulation defines the company’s obligations depending on the role it plays in the supply chain, while the CLP Regulation – its obligations related to the Classification, Labeling and Packaging of chemicals. Under the new provisions, the obligations of all companies in the supply chain have been changed. Manufacturers and importers that place chemicals on the market must ensure the safety of all operators in the supply chain, adequately informing them of the risks and defining risk management measures. New responsibilities have been imposed on all actors in the supply chain, including downstream users and distributors of chemicals – the numerically largest groups of companies in the supply chains that are present in every industry. Most of downstream users and distributors of chemicals belongs to the sector of small and medium sized enterprises, that have limited resources for expensive and time-consuming trainings, and what more the offer of non-commercial trainings in the field of CSM is insufficient.
Assessment of the state of implementation of REACH and CLP Regulations leads to the conclusion that either people responsible for chemical safety among downstream users (DU) and distributors (D) of chemicals are insufficiently trained or lack the knowledge and understanding of EU legislation in this field. There is a widespread belief that the new EU regulatory framework for chemicals is too complex and, moreover the regulations change over time, causing additional problems for companies.
Companies declare problems with defining their legal obligations under REACH and CLP Regulations and insufficient skills, for examples, in classifying chemical mixtures and assessing exposure in the work environment. A survey carried out by the European Chemical Agency in 2010 and 2013, showed that many companies lacked the required safety data sheets (SDS). Some companies have not met the SDS requirements for language, structure and content, and the obligation to pass them down the supply chain. In some companies, unregistered substances were used but the required information was not provided down the supply chain.
Preliminary survey and assessment of the needs of the workplace regarding CSM training showed that demand in this area is high. In response to such needs, the team of the Department of Chemical Safety, the Institute of Occupational Medicine in Lodz, together with the Lodz University of Technology and partners from Germany (Oekopol Institute), Romania (Romtens Foundation) and Greece (Prolepsis Institute), implements the 3-year (01/09/2017 – 31/08/2020) project Chemical Safety Management Training Hub for Chemicals Users – ChemSM-Hub co-founded from European funds under the EU Erasmus+ Programme.
The project consortium is structured in such a way that the EU Member States that make up the consortium present different levels of development of the chemicals market and different experiences in applying EU rules. Table 1 describes the organizations included in the project consortium.
The main objective of the project is to support companies in fulfilling the provisions of REACH and CLP Regulations by preparing a training program in CSM available free of charge from the e-learning platform (ChemSM-Hub) and the mobile application.
It is assumed that the project will contribute to the promotion of online training methods that are not institutionalized but depend on the individual needs and time of the people concerned. The creation of such modern training hub for employees working with chemicals will increase their qualifications and market competitiveness. It is assumed that the ChemSM-Hub will enable to study the subject at any time and place using a laptop, tablet or smartphone and will be a great alternative to classic classroom training.
The aim of the project
The strategic aims of the project are strengthen competences of target groups in the field of CSM, increase awareness of relevant professional communities on the new European legislation on CSM (REACH, CLP Regulations), enhance trainers’ skills in creating and conducting training in CSM in partner countries. We intend to achieve the above aims by providing free access to innovative, comprehensive training program available from the e-learning platform (ChemSM-Hub) that was designed for both self-education and blended training. The project is expected to increase knowledge concerning the downstream users obligations imposed on them under REACH and CLP Regulations, including adaptation of safety data sheets for chemical mixtures to new legal requirements, the main procedures of REACH and CLP Regulations, as well as knowledge about various sources of support for downstream users, including the European Chemicals Agency.
Project target groups
Based on the state-of-the-art analysis, it has been established that large chemical companies are usually very well prepared to fulfill the obligations under REACH and CLP, while among DU and D of chemicals there are many small and medium enterprises (SMEs), with much less awareness of chemical hazards, not having funds for training and often without external support. The above-mentioned became the basis for selecting the project target groups.
Primary group of users/beneficiaries:
Company belonging to the category of downstream users (DU) and distributors (D) of chemicals, mainly small and medium enterprises.
Employers and employees responsible for CSM, including OSH specialists, among downstream users of chemicals, containing professional and industrial chemical users, formulators, fillers, article producers, craftsmen, service providers, distributors of chemicals.
Secondary group of users/beneficiaries:
State authorities, like sanitary inspection and labor inspection.