Development Chemicals Management Tool for REACH Compliance check of mining chemicals by Dutch operators.
Under the operational chemical management framework agreement, we supported NOGEPA (Taskforce Chemicals) and the State Supervision of Mines (SSM) as competent authority for the upstream production of natural gas and crude oil to optimise the permitting procedure of mining chemicals under the Dutch Mining Law and REACH (see details other reference)
In 2013, in parallel to the optimisation process, Jongerius Consult developed with the NOGEPA Taskforce Chemicals and representatives of EOSCA (Suppliers of mining chemicals) a Chemicals management tool how the Suppliers and Operators could work together to check and document the REACH Compliance status of the mining chemicals used. The Chemicals Management Tool focusses on the key processes under REACH, whereby the Supplier has to organise his REACH Compliance checks (e.g. Registrations etc.) and provide a REACH Compliant SDS to the Operators. The Operators need to take care of their downstream user requirements based on the SDS information as worked out under REACH. The NOGEPA Chemicals Management Tool is developed in MS Excel with clear instructions (in text and flow charts) and documentation template for the Stakeholders involved. The Tool is discussed and agreed upon with the SSM.
Since 1-1-2014, the NOGEPA Chemicals Management Tool is made available to Member Companies by NOGEPA. The Tool can be used as such or can be used as definition to check and where necessary upgrade the internal Chemicals Management system under the own responsibility of the Dutch Operator. As such, the Dutch Operator can demonstrate a REACH Compliance verification process of the mining chemicals in close interaction with the Suppliers. This is a required element from REACH as well as for the optimised permitting procedure of mining chemicals under the Dutch Mining law.