To comply with the requirements of the REACH legislation, Infineum companies will submit registrations for all appropriate registerable substances contained in the products we supply by the relevant registration deadline and work with our suppliers to ensure they will do the same.
As part of the registration, we are required to take account of the uses of our substances and, for those that are hazardous and manufactured or imported to the European Union (EU) at greater than 10mt, to conduct a risk assessment known as a Chemical Safety Assessment which includes the development of recommended operating conditions and risk management measures which reduce the exposure to a level which is considered acceptable.
Following industry recommended processes, Infineum have been working within our own and with related downstream user trade associations to define a list of applications that our products are used for. In this way we expect to have captured the majority of downstream uses so that our customers using products in intended ways can feel confident that their use will be covered within the REACH registrations of the constituent substances.
In order to simplify the communication process a joint (Technical Association of the European Lubricant Industry (ATIEL) / Additives Technical Committee (ATC)) working group, chaired by Infineum, has developed generic use groups for specific applications. This is possible because specific applications which appear to be different can be grouped by the way that exposure to man and the environment occurs, and the risk can be controlled in similar ways.
In order to confirm that your uses of our products will be covered by our and our supplier’s registrations we have provided a reference table which you can download below. This table allows you to use filters to find the Infineum product you purchase and the ATIEL / ATC "Use Group(s)" to which this product has been assigned. The table also includes worksheets which detail the specific applications covered by each of the ATIEL / ATC "Use Group". If your use of our product is included within the list of applications covered by the ATIEL / ATC "Use Group" you may feel confident that it will be taken into account in the appropriate registration(s) as long as safe use can be demonstrated. If this is the case, then you need take no further action.
Download the reference table for Lubricant Products (When clicking on the link please choose "save as" to save the table in your disk).
Download the reference table for Additised Fuels Products (When clicking on the link please choose "save as" to save the table in your disk).
However, if you wish to refer to the details included in each ATIEL / ATC Lubricant or ATC Additised Fuel Use Groups, please refer to the spreadsheet entitled "Lubricant or Additised Fuel Use Descriptor Table in DUCC format" in Section 7.3 of the ATIEL REACH (for Lubricants) or ATC REACH (for Additised Fuels) web page in which we have collated all of the Use Descriptor information for each Exposure Scenario Title i.e. a description of activities covered together with a listing of the specific Use Descriptor codes [i.e. Sector of Use (SU), Process Category (PROC), Product Category (PC) and Environmental Release Category (ERC)].
http://www.atiel.org/Reach_GES.htm
http://www.atc-europe.org/
Again, if your lubricant or fuel application is covered by the relevant ATIEL / ATC Lubricant or ATC Additised Fuel Use Group and associated Use Descriptor information - there is no need to take further action since it is expected that your use will be covered by the upstream suppliers in their registration dossier.
However, if you consider your use as non-standard for the product – we encourage you to review the ATIEL / ATC Lubricant or ATC Additised Fuel Downstream Users of Chemical Co-ordination Group (DUCC) Table to identify an appropriate Use Group and advise us of the product name and relevant Use Groupings using
REACH@infineum.com
Please do NOT provide confidential information on the commercial application of the product or any other commercially sensitive information.
Please be aware that there is a minimum notice period of 12 months required for uses not already identified, which means that for substances with a December 2010 registration, feedback and alignment is required by 30th November 2009.