Consumers

DEVELOPMENT OF CONSUMER GESs

ESIG has not developed "ready made" GESs like those described for workers.  Rather, ESIG has worked to develop a tool that enables users to develop their own consumer CSA/ES for a particular area of use that can be based upon the results of the various communication and use mapping activities that have been undertaken with major DU groups (e.g. the consumer use of coatings, which is in turn described by a set of product categories and sub-categories).

The tool takes the default assumptions and algorithms (equations) described in the ECETOC TRA and further develops these in a manner described in Appendix F of ECETOC Technical Report 107 i.e. it introduces refined default values for those product categories relevant to solvents (as described in chapter R12 of the REACH TGD).  The ESIG consumer CSA tool is Excel based.  This enables users to control the level of detail/complexity considered appropriate for any GES (which is a compilation of the product categories and subcategories considered relevant for the particular use).

The tool is supported by extensive user instructions. However, because the tool addresses all Product Categories potentially applicable to solvents, then users will to need to remove redundant product categories and sub-categories that are not appropriate for inclusion during the construction of the CSA/ES for any generic consumer use.  Additional product categories/sub-categories may also need to be added if they are not addressed within the tool (Note: while all PCs listed in the current version of R12 are included in the tool, it does not include those identified in earlier versions of R12 where more extensive lists of PCs were included.

Similarly, if users consider that the description of a PC or sub-category is inaccurate or inappropriate (e.g. pesticide applications are assumed to be via pressure spray whereas a particular presentation may be via trigger spray or solid application), then users will also need to refine the default assumptions consistent with information available.  Therefore the tool, while straightforward to use, cannot therefore be considered to be suitable for use by non-experts.  It delivers the CSA and related ES in a manner that is transparent and consistent with the expectations of chapter R15 of the TGD.  But it does require an understanding of the basis of how consumer exposures are determined and associated risks evaluated.

One major advantage of the tool for users, especially those Registering substances under REACH, is its ability not only to calculate the RCR's for each use (including sub-categories of use) but to "auto-correct" the product concentration for particular use to a safe level (i.e. ensuring an RCR of <1 when calculated across all relevant exposure routes for that use).  Furthermore, the tool also incorporates a capability to auto-populate the supporting narrative Exposure Scenario using all relevant exposure determinants in order that this information is consistently communicated to downstream users in a simple and structured way such that they are able to scale at the formulator level when appropriate.