Under REACH, downstream users must respect use conditions and risk management measures recommended by the manufacturers and the importers. So, as soon as a safety data sheet (SDS) is received, the user of a hazardous substance or mixture must check:

• the compliance with the described use and respect of the exposure scenario(s),
• the respect of the risk management measures,
• the compliance with a granted authorisation or restrictions.

This checking is done according a procedure by stages.

The first step consists in checking that the intended use of the substance corresponds to an use described in the section 1.2 of the SDS. If it is an extended SDS with one or more exposure scenarios, the compliance of the use with one of the described exposure scenario must also be checked.

The second stage amounts to control that the actual conditions of use match the conditions of safe use described in the exposure scenarios.

If the intended use is not covered in the SDS and in the exposure scenarios or if the actual conditions of use do not comply with the risk management measures, the user must take action. He may either:

• ask the supplier to amend the chemical safety report (CSR) and to develop a new exposure scenario to make the use an identified use (see Duty to communicate);
• adapt his activity: he can change his use into an identified one, improve the use conditions to respect the risk management measures or try to substitute the substance with a less hazardous one;
• look for another supplier providing a scenario covering his use or ready to develop a new scenario;
• make his own chemical safety report in accordance with Annex XII of REACH. The user generates then an exposure scenario covering his use. He must attach this scenario to his own SDS and notify ECHA for his use. In some cases, in particular when the substance is used for product and process oriented research or when the total used amount is less than 1 tonne per year, the user may be exempted to prepare a CSR but he shall always notify. Lastly, the third check involves the substances subject to authorisation or concerned by use restrictions (see Usable substances). The section 15 of the SDS enables the user to know if he is involved by such measures. If it is the case, he must check that his use complies with a granted authorisation or respects the restrictions fixed for the substance.

Deadlines

If the uses are covered, the user has 12 months to implement the measures communicated in the extended SDS starting from its receipt. If the uses are not covered, the user has 12 months to carry out his own chemical safety assessment (CSA) and to implement the related exposure scenarios.