Nalco Europe B.V.

1
REACH Together

• Nalco Europe B.V.

• Meeting the challenge Our strategy
• Organize
• Invest
• REACH along the Chain

Huw P. JonesREACH Program Manager26th August
2007
2
REACH Threats

• German VNCI estimate billions of Euros of cost
  will enter the supply chain in coming years
• CEFIC estimate 1030 of substances may disappear
• Increased regulatory burden - Dossiers will stay
  open and will need tracking and developing
• Will be harder to sell certain chemistries e.g.
  CMRs
• Increased cost, regulatory and reformulation may
  force smaller companies to close

3
Scope
Nalco ABC
Preparation/Mixture
Substance
Mercapto-ethanol
Benzene
OH
Octanol
OH
Applies to the substance, not the mixture 3
registrations
4
Registration

• Working in partnership, companies MUST provide -
• - Dossier of physio-chemical and toxicological
  information
• Chemical Safety Report to cover each use and
  fate
• The bigger the volume, the more data is required
• Thresholds are
• Tonnage per year 1,000 - 100 - 10 - 1
• Very high concern Carcinogens, mutagens,
  reproductive toxins endocrine disruptors
  persistent, bio-accumulative toxic chemicals
• Phased over 11 years with high tonnage / high
  concern considered first

5
Registration time-line
Chemical Safety Report
Dossier x
Pre-registration
Agency start up
10 -100 T.Yr
1 -10 T.Yr
100 1000 T.Yr

• gt1000 T.Yr
• gt1 T.Yr CMR
• gt100 T.Yr PBT/vPvB

01-06 2008
01-06 2007
01-06 2013
01-06 2010
01-06 2018
01-12 2008
Nalco is on track to meet its registration
obligations
6
REACH Program
INFORMATION SYSTEMS
LEGAL
MARKETING
SHE
REACH
RESEARCH
SALES
PROCUREMENT
MANUFACTURING
Nalco recognizes that REACH is business critical
to Nalco our customers
7
Organize for REACH
Deliver REACH compliance in a timely and cost
effective manner whilst supporting our
customers needs
Chair by VP EuropeBU General managersMarketing
managers Research DirectorFinance
DirectorProcurement directorLegal
counselManufacturing director
Steer REACH David Johnson Deborah Hockman VPs
Operations SHE
Work REACH Huw P. Jones
Supply Chain (SC) REACHNelma Tavares
Communicate REACHLian Van Baal
Inventory 4 REACHJim Ferguson
Toxicology 4 REACHRicky Stackhouse
Cosmo CASE STUDYHuw P. Jones
Nalco fully supports REACH has the people
programs to meet this new regime
8
Program segments

• Programme breaks down into a number of segments
• Nalco will in many cases sits at supply chain
  inter-face

9
Investing in REACH

• Current inventories generated manually
• Nalcos planned investments include an automated
  SAP solution
• And adoption of ICUCLID 5.0 software for
  registration dossiers

10
REACH along the chain

• Strategy
• Supplier focus
• Customer focus
• Hear Nalco
• Effective communication is key

Customers
Suppliers
Management teams manufacturing
Sales Marketing SHE Research Development
Procurement
Hear
Establishedreach_at_nalco.com
11
Customer focus

• General customer enquiry letter
• SDS REACH Statement
• Integrate clear REACH guidance into Nalco Direct
  web offerings
• reach_at_nalco.com established
• Customer seminars
• Face to face presentation for key accounts
• Bulletin available with core messages
• Webex seminars
• As above for other customers but run as Webex
  conference

Sales Briefing QA
Customer Brochure
Secured supply the process link
12
Supply Chain REACH- Safety Data Sheets

• Requirements
• Email address of the person responsible for the
  SDS
• Sequence of chapter 2 and 3 is reversed
• Gradually over time all SDSs will be extended
  with exposure scenarios for intended uses
• How is Nalco going to implement and be legally
  compliant?
• New lay out is ready and will be implemented per
  1-6-2007
• Will change to new SDS for each new product/SDS
  or after significant change
• Gradually over time all SDSs will change to new
  lay out (deadline 1-12-2010)

13
Supplier focus - REACH UP

• Open communication lines
• Integrate REACH messages into Nalco Direct web
  offering
• Briefing bulletin on Nalcos expectations
• reach_at_nalco.com established
• REACH integrated into supplier contracts
• REACH integrated into toller contracts
• Establish database to capture supplier responses
• Establish SAP capability to hold and use supplier
  responses including REACH contacts, use fate
  and registration response

14
Supplier focus- Secured Supply
Confirm in writing that each chemical you supply
will be pre-registered Highlight any chemicals,
which in your view will meet the definition of
carcinogen, mutagen or reproductive toxin (CMR)
category 1 2 or the persistent,
bio-accumulative and toxic (PBT/vPvB)
definitions Highlight if your supply of any
chemical is likely to exceed 1,000 tonnes per
year Highlight any chemical(s) for which Nalco
and its groups companies account for a
significant proportion (nominally more than 25)
of your total EU sales volume Provide contact
details of the person or person(s) responsible
for the day-to-day running of your REACH program
and to whom questions information should be
directed
15
Supplier focus- 2 Steps, 3 Waves
Use Fate communication
Step 2
Top 100 Suppliers- 80 spend
TollersandNon EU Suppliers
Low volume Suppliers
Step 1
Open lines
Chase
Chase
Chase
Wave 1
Wave 2
Wave 3
16
Supplier focus- Responses

• Feedback so far
• Many have no defined contact centre
• Few will commit to register although many will
  now pre-register
• Supply chain complex with multiple suppliers
• Some initially give only general responses
• Too early to exchange use fate information as
  no EU Guidance

Nalco will pre-register all our chemicals and
also no response chemicals switch suppliers
17
Downstream UsersUse Fate

• To be developed
• We will identify the use and fate of our products
  via Nalco Marketing and RD
• We will verify the outcome with our customers

Downstream use to be developed Scheduled
beginning 2008
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Exposure Patterns
Consumer
Professional
Industrial
Water
Environment
Air
Waste
ClosedSystem
MatrixInclusion
Non-Dispersive
Dispersive
Soil
Accidental
Human
Occasional
Oral
Inhalation
Dermal
Continuous
19
Use Category ?
Use Category

Industry Category
20
REACH Ahead
Registration of1,000 T.Yr chemicals
Identify use fate information for all
chemicalsCommunication use fate to suppliers
customersComplete key account
briefingsPre-register all Nalco
chemicalsInitiate tox testing on all New 1,000
T.Yr chemicalsEstablish consortia for high
volume chemicals
Registration of100 T.Yr chemicals
Registration of1 T.Yr chemicals
Pre-register Nalco chemicals
2008
2009
2010
2013
2018
Complete toxicity testing on all 1,000 T.Yr
chemicals Draft CSA/CSRs and dossiers for 1,000
T.Yr chemicalsData exchange SIEF formation
target 100 T.Yr chemicalsIdentify non-supported
supplier chemistry usesDevelop Initiate
reformulation strategy
Brief internal teams on programMake an inventory
of all Nalco chemicals Develop SAP Inventory
toolREACH ALONG THE CHAIN - Supplier
communication Draft customer communication
material including web offeringReview organize
all existing toxicity dataCommence work on
analytical substance supportDevelop budget
forecast make strategic support hires Modify
MSDS template