Safe Use of Mixtures Information (SUMI) in the cleaning sector
Introduction and problem setting
Ensuring the safe use of hazardous substances is an integral part of the REACH Regulation. Manufacturers or importers of chemical substances in Europe have the obligation under REACH to determine how the substance can be used safely throughout the supply chain, and need to perform a chemical safety assessment for all uses of the substance in order to determine appropriate risk management measures. However, mainly because of long, complicated supply chains and a lack of standardized communication on safe use, these risk management measures often do not reach end-users working with chemical products. Meanwhile, end-users of chemical products often do not have relevant knowledge on chemistry and toxicology to easily determine appropriate risk management measures themselves. Especially SME company’s, like a small family cleaning business, would therefore be helped significantly if risk management measures for the safe use of a professional cleaning product would be properly communicated to them.
The REACH Regulation puts the burden of determining safe use conditions at the link in the supply-chain with (usually) the most extensive knowledge on toxicology the chemical substance and its hazardous properties: the manufacturer/importer. Formulators of cleaning products receive the results of the chemical safety assessments performed by their ingredient suppliers through the Safety Data Sheet (SDS) and its annexes. The information in such an SDS and its annexes is however often too complicated to directly forward to customers using the formulators’ cleaning products. In order to simplify and harmonize this communication to end-users of chemical products, a communication format was developed: Safe Use of Mixtures Information (SUMI).
The SUMI communication method was developed by the Downstream Users of Chemicals Co-ordination (DUCC) group, a collaboration between several European industry sector associations. A SUMI is a document containing easy-to-read conditions of safe use for a chemical product (mixtures). In order to have relevant and understandable SUMIs for end-users, many sector associations are developing their own, standardized set of SUMIs for typical uses of chemical products within that sector.
One of the first sectors to implement SUMIs is the detergents sector. Particularly in the Netherlands where the Dutch association for cleaning and maintenance products (NVZ – Clean, Hygienic, Sustainable) was heavily involved in the development of the SUMI communication method. NVZ has collaborated with the local cleaning company association to ensure proper use of the SUMIs, and collaborated with the Dutch inspectorate on occupational health & safety (iSZW) to ensure that the approach also matches with obligations from the Dutch occupational health & safety legislation.
There are now 21 SUMIs developed for professional and industrial cleaning product applications (e.g. the use of a corrosive drain unblocker, manual cleaning with a non-corrosive, non-irritant all purpose cleaner). A formulator of a professional or industrial cleaning product first determines, from the SDSs of the hazardous ingredients in the mixture, which SUMI(s) are applicable for the product, and ensures that the ingredients are within the safe concentration ranges specified by the ingredient suppliers. The applicable SUMIs are then communicated via the SDS of the cleaning product to the end-user. End-users can in turn be assured that if they comply with the safe use conditions in the SUMI(s) (i.e. wear appropriate personal protection equipment if necessary, comply with the maximum duration requirement, etc.), that the product can be used safely.
Although this example from the professional and industrial cleaning industry is not directly applicable for carcinogenic, mutagenic or reprotoxic (CMR) substances, the SUMI communication method itself (based on obligations from the REACH Regulation) can be used for CMR substances as well.