WEBSITE CURRENT VERSION 3
Number	Changes	Date
4	Lubricants Application tables revised DUCC table revised	February 2010
3	Applications table updated to version 22 20Oct09 Summary heading added General text revision Timeline updated DUCC table inserted Useful links section added Q&As section added	November 2009
2	Step by step guide Summary use descriptor codes added	July 2009
1	Original	June 2009

1. Background and Objectives

Members of ATIEL (Technical Association of the European Lubricants Industry/Association Technique de L'Industrie Européenne Des Lubrifiants) have been working with members of ATC (Technical Committee of the Petroleum Additives Industry in Europe) to develop and communicate information on use descriptors and generic exposure scenarios (GES) for common lubricant end uses to all those involved in the lubricants supply chain.

The information provided in these web pages is targeted at suppliers to the lubricants industry, especially EU manufacturers and/or importers of substances and/or formulated products and to our downstream users (customers). In particular it is aimed at substance manufacturers and importers who need to prepare Chemical Safety Assessments & Reports (CSA/CSR) for REACH registrations and to anyone developing extended Safety Data Sheets (eSDS) for lubricant additives and finished lubricants. Downstream users may wish to use this site to verify the types of lubricant applications that are likely to be covered by registrants of substances present in finished lubricants.

The objective of the ATIEL/ATC Generic Exposure Scenario Working Group (ATIEL/ATC GES WG) in developing these generic exposure scenarios (GES – see Glossary for definition) is to offer everyone in the lubricants supply chain a standardised format for their exposure scenarios and a standardised language and terminology to use in those documents. No one is obliged to follow these recommendations but we believe that by doing so you will greatly improve communication with your downstream users and/or your upstream suppliers. In doing so, it is expected that they will receive documents in a format and using a set of terms with which they are already familiar. Using these recommendations should also make it very much easier for you to develop Exposure Scenarios for your own products (if necessary) and prepare the extended Safety Data Sheet (eSDS). The goal of this project is therefore to standardise communication in the lubricants supply chain and considerably reduce your workload thereby saving you time and effort.

The first version of these web pages was posted in June 2009. The information will be updated and expanded over the coming months. In order to continually improve the information provided here, the ATIEL/ATC GES WG welcomes comments, questions and suggestions from trade organisations or individual companies involved in the lubricants supply chain. Please send comments (clearly marked for the attention of the ATIEL/ATC GES WG) to: info@atiel.org.

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2. Outline of Content and Update History

1.	Background and Objectives	Version 1 posted June 2009
2.	Outline of Content and Update History	Version 1 posted June 2009
3.	ATIEL/ATC GES Working Group ‘Workflow’	Version 1 posted June 2009
4.	Requirement for Exposure Scenarios	Version 1 posted June 2009
5.	How to Use this Information - General	Version 1 posted June 2009
6.	Information for Suppliers
6.1	Step by Step Guide	Version 1 posted June 2009 Updated July 2009
6.2	Lubricant Applications Table	Version 1 posted June 2009
6.3	Lubricant Use Descriptions for Tier 1 Exposure Assessment Tables
6.3.1	Workers (Industrial/Professional)	Version 1 posted June 2009
6.3.2	Consumers	Expected 3Q 2009
6.3.3	Environment	Expected 2Q 2010
6.4	Additional Guidance for Suppliers	Summary of Use Descriptor Codes for each ATIEL ATC Lubricant Use Group inserted in July 2009
7.	Information for Customers
7.1	Step by Step Guide	Version 1 posted June 2009
7.2	Lubricants Application Table	Version 1 posted June 2009
7.3	Lubricant Use Descriptions for Tier 1 Exposure Assessment Table
7.3.1	Workers (Industrial/Professional)	Version 1 posted June 2009
7.3.2	Consumers	Expected 3Q 2009
7.3.3	Environment	Expected 3Q 2009
8.	Generic Exposure Scenarios
8.1	Lubricant Use Group A	Expected 1Q 2010
8.2	Lubricant Use Group B	Expected 1Q 2010
8.3	Lubricant Use Group C	Expected 1Q 2010
8.4	Lubricant Use Group D	Expected 1Q 2010
8.5	Lubricant Use Group E	Expected 1Q 2010
8.6	Lubricant Use Group F	Expected 1Q 2010
8.7	Additional Valiation Information Supporting Use of GES	Expected 1Q 2010
9.	Acronyms/Glossary	Version 1 posted June 2009
10.	Useful Links	Version 1 posted June 2009
11.	Q&As	Posted Nov 2009

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3. ATIEL/ATC Generic Exposure Scenario Working Group – Workflow

The working group has been active for over 2 years. Progress to date and ongoing activities which will lead to updates to these web pages are summarised below.

	WORKFLOW STEP	Status as of October 2009
1.	Create a comprehensive list of all lubricant applications (in industrial/professional and consumer settings)	Complete
2.	Assign high level ‘exposure determinants’ to all lubricant applications	Complete
3.	Group applications by similar ‘exposure determinants’	Complete
4.	Test groupings and generate ‘Lubricant use descriptions for Tier 1 Exposure Assessment’ (using standard terminology found in Guidance on Information Requirements and Chemical Safety Assessments) – see Section 6.3 and 7.3
	a. Workers (industrial / professional),	Complete
	b. Consumers and	In progress
	c. Environmental Compartments	In progress
5.	Add use descriptions for other relevant life cycle stages:
	a. Blending,	Complete
	b. waste disposal	In progress
6.	Communicate use descriptors in DUCC format	Complete
7.	Add information on typical operational conditions and risk management measures	In progress
8.	Publish initial information on ATIEL public  website, including separate guidance for Suppliers and Downstream Users on  their recommended use of this information	Complete
9.	Request feedback from the Suppliers and Downstream Users on potential gaps, errors and suggested amendments	In progress
10.	Create Generic Exposure Scenarios( based on current good practice) for grouped applications	In progress
11.	Use recommended tools (e.g. DPD+ Methodology) to validate the Generic Exposure Scenario for each grouped application	In progress
12.	Use recommended tools (e.g. ECETOC TRA) to characterise the risk for a typical lubricant additive to demonstrate the use of the information by manufacturers/importers  and to ensure validity of the process	In progress
13.	For each grouped application propose adequate risk modifiers for Tier 2 Exposure Assessment, where Tier 1 default values are shown to be inappropriate	Not started
14.	Environmental exposure scenarios	In progress

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4. Requirement for Exposure Scenarios

REACH requires EU manufacturers and importers to register each of their chemical substances with the European Chemicals Agency (ECHA). Each registration must include a full toxicological assessment of the hazards that the substance presents to man and the environment and for hazardous substances an assessment of risk to man and the environment. The risk assessment must cover the manufacturing process (if produced in the EU), each supported (Identified) use and its final disposal as waste. REACH refers to these risk assessments as Chemical Safety Assessments (CSA) and their output as a Chemical Safety Report (CSR).

All registered substances will be evaluated for their hazard. If a substance is determined to be non-hazardous an Exposure Scenario is not required. If the substance is determined to be hazardous however (including a PBT or vPvB) then an Exposure Scenario will be required if the substance is produced and/or imported at 10 MT or greater.

The first stage in this process is the creation of an Exposure Scenario (ES) for each phase of the life cycle of the substance. The Exposure Scenario describes the life cycle phase being assessed (e.g. substance manufacture), breaking it down into individual process steps, identifying the degree to which humans or the environment are exposed to the substance at each step and finally how that exposure can be controlled by applying appropriate Operational Conditions and Risk Management Measures. There will therefore be a separate Exposure Scenario for the manufacturing stage (if required), for each different Identified use of the substance and for the final disposal of the substance as waste. (1)

In an attempt to simplify this process for companies in the lubricants supply chain, the WG has used the methods described in the European Chemicals Agency (ECHA) guidance on Information Requirements and Chemical Safety Assessments to condense several hundred different applications of lubricants and lubricant additives to a much smaller number of generic uses. This was possible because many of these applications, though ostensibly different, are actually very similar in terms of human and environmental exposure and can therefore share the same set of Use Descriptors.

(1) Although “wastes” are controlled under the European Waste regulations rather than by REACH, the CSA/CSR should include an assessment of the extent to which humans and the environment are exposed to the substance during final disposal.

In an attempt to simplify this process for companies in the lubricants supply chain, the WG has used the methods described in the European Chemicals Agency (ECHA) guidance on Information Requirements and Chemical Safety Assessments to condense several hundred different applications of lubricants and lubricant additives to a much smaller number of generic uses.  This was possible because many of these applications, though ostensibly different, are actually very similar in terms of human and environmental exposure and can therefore share the same set of Use Descriptors.

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5. How to Use this Information – General Guidance

The communication of uses according to the Use Descriptor System is an essential step in developing a Chemical Safety Assessment. In view of the complexity of the registration process (i.e. significant numbers of substances, manufacturers/importers and uses), a common framework is considered necessary to harmonize communication within the lubricants supply chain to ensure effective and efficient information exchange on Identified Uses between Manufacturers/Importers and Downstream Users. 

The following two sections advise on how Suppliers (Section 6) and Downstream Users (Section 7) within the lubricants supply chain can use the information provided in these web pages (in conjunction with the ECHA guidance if necessary) to ensure that the registration dossiers of substances used in the lubricant industry sector cover all the relevant Identified Uses and aid in the generation of Exposure Scenarios.

The guidance is divided between Suppliers and Downstream Users since it is anticipated that the information will be used differently depending on your position within the lubricants supply chain. It is recognised that individual companies can be both a Supplier and a Downstream User and so might need access to both sections of this site.

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6. Information for Suppliers
6.1 Step by Step Guide

It is expected that suppliers to the lubricant supply chain will be aware of approximately 80% of the uses of their substances/products. The ATIEL/ATC GES WG therefore recommends that EU manufacturers and/or importers responsible for the registration of substances and formulators adopt the CEFIC/FECC-endorsed “top-down” communication workflow for Identified Uses and associated Exposure Scenarios. The following steps should help you to establish the Identified Uses which you may be asked to cover in your registration dossier for substances you manufacture or import (or pass up the supply chain to the manufacturer/importer if you are a formulator).

Step 1: Identify the lubricant applications (family and specific application) in which your substance/product is used (e.g. Metalworking, Corrosion protection – water based) by referring to the Lubricants Application Table (Section 6.2). Make a note of the Grouping (A – F) that has been allocated by the WG to each application. For example:

LUBRICANT APPLICATION		ATIEL-ATC LUBRICANT USE GROUP
Family	Specific application
Metalworking	Corrosion protection - water based - diluted	C

Step 2: Refer to the spreadsheet titled ‘ATIEL ATC Exposure Scenario Information in DUCC Format’ in Section 6.4 and identify the use descriptors -  Sector of Use (SU), Process Category (PROC), Product Category (PC) and Environmental Release Category (ERC) -  that have been assigned to the Groups you selected.

Additional information to assist with the construction of Exposure Scenarios for workers is given in the ‘Lubricant Use Description for Tier 1 Exposure Assessment’ Table (Section 6.3.1)  Similar information for consumer uses and environmental release will  be given in sections 6.3.2 and 6.3.3  in a future  update to these web pages.

Step 3: Confirm within your own organisation that you intend to develop Exposure Scenarios covering these Identified Uses in your registration dossier, or that this will be included by the substance manufacturer/importer if you are a formulator.

Step 4: Communicate the Identified ‘Uses and Exposure Scenarios’ you intend to support (or your supplier intends to support) to your Downstream Users as soon as possible and at the latest by the end of 3Q2009 for substances to be registered by 01 December 2010.

Suppliers to the lubricants industry should note that all substances used in lubricant applications will need to be registered for the Identified Uses allocated to Group A (Formulation) in the Lubricant Use Descriptions for Tier 1 Exposure Assessment Table (Section 6.3.1) and at least one other from Groups B to F.

6.2 Lubricant Applications Table

ATIEL-ATC Lubricant Applications Table (01-Feb-10)

6.3 Lubricant Use Descriptor for Tier 1 Exposure Assessment Tables

6.4 Additional Guidance for Suppliers

The following table summarises use descriptor codes for each of the ATIEL-ATC Lubricant Use Groups using the format recommended by the Downstream Users of Chemicals Coordination group (DUCC).

ATIEL-ATC Lubricant DUCC Table (8-Jul-09)

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7. Information for Customers/Downstream Users
7.1 Step by Step Guide

It is expected that suppliers to the lubricant supply chain will be aware of approximately 80% of the uses of their substances/products. The ATIEL/ATC GES WG therefore recommends that EU manufacturers and/or importers responsible for the registration of substances and formulators adopt the CEFIC/FECC-endorsed “top-down” communication workflow for Identified Uses and associated Exposure Scenarios. It is the intention of the ATIEL/ATC GES WG members to cover, and/or encourage their suppliers to cover, the supported lubricant applications and Use descriptors included in the Lubricant Applications Table (Section 7.2) and the the Lubricant Use Description for Tier 1 Exposure Assessment Tables (Section 7.3) in their registration dossiers.

The following steps should help you identify whether your use of a substance/product supplied to you has been assessed as part of this project and assigned a set of Lubricant Use Descriptors by the WG:

Step 1: Refer to the Lubricants Application Table (Section 7.2) to identify the Group (B – F) that has been allocated by the ATIEL/ATC GES WG for your Lubricant Application (i.e. Family and Specific Application). For example, the lubricant application ‘Metalworking, Corrosion protection – water based - diluted’ has been assigned to Group C as per below extract from the Lubricants Application table.

LUBRICANT APPLICATION		ATIEL-ATC LUBRICANT USE GROUP
Family	Specific application
Metalworking	Corrosion protection - water based - diluted	C

Step 2: Refer to the Lubricant Use Description for Tier 1 Exposure Assessment Tables (Secton 7.3.1) to identify the Sector of Use (SU) and Process Category (PROC) that has been assigned to the Group you selected.  (Note that additional information on consumer uses and Environmental Release Category (ERC) will be provided in section 7.3.2 and 7.3.3  in a future  update to these web pages).

Step 3: If your lubricant application is covered by the provided Use Descriptors, there is no need to take further action since it is likely that your Use will be covered by the upstream suppliers in their registration dossier. In this case it is highly recommended that you do not contact your supplier at this stage but instead wait for them to communicate this information to you in line with the CEFIC/FECC “top-down” communication workflow. [Important note - it is expected that you should receive such information from your immediate supplier by the end of 3Q2009. If you have not received any information from them by then it would be appropriate to check with them that your particular use will be covered].

Step 4: If your lubricant application is not adequately described by Steps 1-3 then it is recommended that you contact your Supplier as soon as possible if you want the manufacturer/importer to include your specific use in their registration dossier. In accordance with REACH you, as a Downstream User, can ask the manufacturer/importer  (even if it is by way of your supplier who may be a formulator) to include your use in the registration dossier. However, this communication has to be completed at least 12 months before the respective registration deadline and meaning that for substances with a 1st December 2010 registration deadline this has to be completed by end November 2009 at the latest. If you decide not to make your particular use known to the manufacturer/importer, or the manufacturer/importer has already informed you that they will not support a particular use because it is deemed not safe, then you may have to develop your own CSA for this use and inform ECHA (see Guidance for Downstream Users), assuming you would like to continue the particular use.

Please note that Step 4 is also a feedback loop that will help in the development of the Lubricant Applications Table. The ATIEL/ATC GES WG has used their best endeavours to ensure that this table covers all the different applications of lubricants and lubricant additives but it is understood that language and nomenclature may differ between individual companies across this sector and so identification of your specific use in the table may be problematic. If you are unable to identify your specific use in the table and you would like to see your particular application included in this project then you should contact  your supplier for further discussions.

7.2 Lubricant Applications Table

ATIEL-ATC Lubricant Applications Table (01-Feb-10)

7.3 Lubricant Use Description for Tier 1 Exposure Assessment Tables

7.3.1 Workers (Industrial/Professional)

ATIEL-ATC Lubricant use description for tier 1 worker exposure assessment (8-Jul-09)

7.3.2 Consumers
Expected 1Q 2010

7.3.3 Environment
See comments in section 6.3.3

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8. Generic Exposure Scenarios for Lubricant Use Groups A – F
Expected 1Q 2010

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9. Acronyms/Glossary

List of acronyms used and what they mean:

Acronym	Title	Description
SU	Sector of Use	Describes the area of use, (e.g. manufacture, public domain, private use, etc.) and also the type of industry (e.g. large scale chemical manufacture)
ES	Exposure Scenario	Covers the set of conditions [usually based around a Process Category (PROC code) for workers, Product Category (PC Code) or Article Category (AC) for consumers or Environmental Release Category (ERC) for the environment] that describe how a substance can be safely used, and which include the necessary operational conditions (OCs) and risk management measures (RMMs) which the M/I considers should be implemented to control the risks to human health and the environment associated with the use. An ES is specific to a substance or product.
GES	Generic Exposure Scenario	Describes the necessary operational conditions (OCs) and risk management measures (RMMs) which should be implemented to control the risks to human health and the environment associated with the use (or uses) of a group of substances/products with a similar risk profile within a general area of industry (and may extend across several PROCs, PCs/ACs or ERCs). By definition, it aggregates the individual Exposure Scenarios for the various tasks and activities that constitute the general use of the substance/product within a specific sector. It is developed by M/Is in partnership with DU associations.
UD	Use Descriptor	The term used in REACH to describe the PROCs, PCs, ERCs and SUs.
PROC	Process category	How the substance is being used (e.g. spraying in industrial settings or applications).
PC	Product category	Type of product (e.g. hydraulic fluid).
AC	Article category	Type of article (e.g. rubber product: tyres).
ERC	Environmental release category	A conservative set of exposure conditions that is intended to ensure that releases to the environment from an use (e.g. industrial use of substances in closed systems) do not represent a cause for concern
SPERC	Specific ERC	An ERC, developed by industry, and based on realistic data and assumptions for a particular use.
OC	Operational conditions	What happens during manufacture or use (e.g. pumped transfer from closed mixing vessel to drum)
RMM	Risk management measures	Actions taken to reduce exposure to an identified hazard (e.g. use of closed vessel to prevent exposure to vapours)
ECETOC (TRA)	Targeted Risk Assessment	ECETOC is a scientific forum for chemical companies to harness their specialist expertise to research, review and assess the ecotoxicology and toxicology of chemicals.
DUCC	Downstream Users of Chemicals Co-ordination	Downstream Users of Chemicals Co-ordination Group. An informal platform of European associations representing a range of downstream industries.

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10. Useful Links

The REACH regulation
www.eur-lex.europa.eu/JOHtml.do?uri=OJ:L:2007:136:SOM:EN:HTML

ATC Additives Technical Committee
www.atc-europe.org

CEFIC
www.cefic.org

CEFIC guidance documents
www.cefic.be/Templates/shwPublications.asp?HID=750

ECHA – European Chemicals Agency
www.echa.europa.eu

ECETOC
www.ecetoc.org

DUCC
www.duccplatform.org/home.html

Any links you select direct you to a website that is not controlled by ATIEL. ATIEL does not endorse, adopt, certify or otherwise validate the information and material contained on the linked website.

11. Q&As

NUMBER	QUESTION	ANSWER
1	I cannot access some of the tables on the website	Contact info@atiel.org
2	What should I do if I cannot find my use on the website	Contact your supplier directly for further information. This information should not be sent directly to ATIEL or ATC

For a comprehensive list of general REACH Q&As please refer to the CEFIC website.

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