Nalco Europe B.V.Nalco Europe B.V.Nalco Europe B.V.Nalco Europe B.V.

REACH TogetherREACH TogetherREACH TogetherREACH Together

Huw P. JonesREACH Program Manager

26th August 2007

Meeting the challenge ~ Our strategy

• Organize• Invest• REACH along the Chain

REACH ThreatsREACH ThreatsREACH ThreatsREACH Threats

• German VNCI estimate billions of Euros of cost will enter the supply chain in coming years

• CEFIC estimate 10–30% 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

ScopeScopeScopeScope

HSOH HS

OH

OH

Benzene

Preparation/Mixture Substance

Applies to the substance, not the mixture = 3 registrations

Octanol

Mercapto-ethanol

Nalco ABC

OH

RegistrationRegistrationRegistrationRegistration

• Working in partnership, companies MUST provide :-Working in partnership, companies MUST provide :-- Dossier of physio-chemical and toxicological - Dossier of physio-chemical and toxicological

informationinformation– Chemical Safety Report to cover Chemical Safety Report to cover eacheach use and fate use and fate

• The bigger the volume, the more data is requiredThe bigger the volume, the more data is required

• Thresholds are:Thresholds are:– Tonnage per year: 1,000 - 100 - 10 - 1Tonnage per year: 1,000 - 100 - 10 - 1– Very high concern: Carcinogens, mutagens, Very high concern: Carcinogens, mutagens,

reproductive toxins & endocrine disruptors & reproductive toxins & endocrine disruptors & persistent, bio-accumulative & toxic chemicalspersistent, bio-accumulative & toxic chemicals

• Phased over 11 years with high tonnage / high concern Phased over 11 years with high tonnage / high concern considered firstconsidered first

Registration time-lineRegistration time-lineRegistration time-lineRegistration time-line

01-06 2013

01-06 2010

01-06 2018

01-12 2008

>1000 T.Yr

>1 T.Yr CMR

>100 T.Yr PBT/vPvB

Pre

-reg

istra

tion

Ag

en

cy sta

rt up 100 – 1000

T.Yr

10 -100 T.Yr

01-06 2008

01-06 2007

Chemical Safety Report

Dossier x

1 -10 T.Yr

Nalco is on track to meet its registration obligations

REACH ProgramREACH ProgramREACH ProgramREACH Program

REACH

MARKETING

LEGAL

SH&E

INFORMATION SYSTEMS

RESEARCH SALES

MANUFACTURINGPROCUREMENT

Nalco recognizes that REACH is business critical to Nalco & our customers

Organize for REACHOrganize for REACHOrganize for REACHOrganize for REACH“Deliver REACH compliance in a timely and cost effective manner

whilst supporting our customer’s needs”

Steer REACHDavid Johnson

Deborah HockmanVPs Operations & SHE

Inventory 4 REACH

Jim Ferguson

Toxicology 4 REACH

Ricky Stackhouse

CosmoCASE STUDY

Huw P. Jones

Supply Chain (SC) REACHNelma Tavares

Communicate REACH

Lian Van Baal

Work REACHHuw P. Jones

Chair by VP EuropeBU General managersMarketing managers

Research DirectorFinance Director

Procurement directorLegal counsel

Manufacturing director

Nalco fully supports REACH & has the people & programs to meet this new regime

Program segmentsProgram segmentsProgram segmentsProgram segments

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

• Current inventories Current inventories generated manuallygenerated manually

• Nalco’s planned Nalco’s planned investments include an investments include an automated SAP automated SAP solutionsolution

• And adoption of And adoption of ICUCLID 5.0 software ICUCLID 5.0 software for registration for registration dossiersdossiers

Investing in REACHInvesting in REACHInvesting in REACHInvesting in REACH

REACH along the chainREACH along the chainREACH along the chainREACH along the chain

Establishedreach@nalco.com

StrategyStrategy

• Supplier focusSupplier focus• Customer focusCustomer focus• Hear NalcoHear Nalco

• Effective communication is keyEffective communication is key

Suppliers Customers

Procurement

Management teams manufacturing

Sales & Marketing

SH&E

Research & DevelopmentHear

Customer focusCustomer focusCustomer focusCustomer focus

• General customer enquiry letterGeneral customer enquiry letter• SDS REACH StatementSDS REACH Statement• Integrate clear REACH guidance Integrate clear REACH guidance

into Nalco Direct web offerings into Nalco Direct web offerings • reach@nalco.comreach@nalco.com established established

Customer seminarsCustomer seminars• Face to face presentation for key Face to face presentation for key

accountsaccounts• Bulletin available with core Bulletin available with core

messagesmessages

Webex seminarsWebex seminars• As above for other customers but As above for other customers but

run as Webex conferencerun as Webex conference

Sales Briefing Q&A

Customer Brochure

Secured supply~ the process link

Supply Chain REACHSupply Chain REACH- Safety Data Sheets- Safety Data SheetsSupply Chain REACHSupply Chain REACH- Safety Data Sheets- Safety Data Sheets

RequirementsRequirements • Email address of the person responsible Email address of the person responsible

for the SDSfor the SDS• Sequence of chapter 2 and 3 is reversedSequence of chapter 2 and 3 is reversed• Gradually over time all SDSs will be Gradually over time all SDSs will be

extended with exposure scenarios for extended with exposure scenarios for intended usesintended uses

How is Nalco going to implement and be legally compliantHow is Nalco going to implement and be legally compliant??• New lay out is ready and will be implemented per 1-6-2007New lay out is ready and will be implemented per 1-6-2007• Will change to new SDS for each new product/SDS or after Will change to new SDS for each new product/SDS or after

significant changesignificant change• Gradually over time all SDSs will change to new lay out Gradually over time all SDSs will change to new lay out

(deadline 1-12-2010)(deadline 1-12-2010)

Supplier focus Supplier focus - REACH UP - REACH UP

Supplier focus Supplier focus - REACH UP - REACH UP

• Open communication linesOpen communication lines• Integrate REACH messages into Nalco Integrate REACH messages into Nalco

Direct web offeringDirect web offering• Briefing bulletin on Nalco’s Briefing bulletin on Nalco’s

expectations expectations • reach@nalco.comreach@nalco.com established established• REACH integrated into supplier REACH integrated into supplier

contractscontracts• REACH integrated into toller contractsREACH integrated into toller contracts• Establish database to capture supplier Establish database to capture supplier

responsesresponses• Establish SAP capability to hold and Establish SAP capability to hold and

use supplier responses including use supplier responses including REACH contacts, use & fate and REACH contacts, use & fate and registration response registration response

Supplier focusSupplier focus- Secured Supply- Secured Supply

Supplier focusSupplier focus- Secured Supply- 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

Supplier focusSupplier focus- 2 Steps, 3 Waves- 2 Steps, 3 Waves

Supplier focusSupplier focus- 2 Steps, 3 Waves- 2 Steps, 3 Waves

Chase ChaseChase

Top 100 Suppliers

- 80% spend

Tollersand

Non EU Suppliers

Low volume

Suppliers

Use & Fate communication

Wave 1 Wave 2 Wave 3

Step 1

Step 2

Open lines

Supplier focusSupplier focus- Responses- Responses

Supplier focusSupplier focus- Responses- Responses

Feedback so farFeedback so far

• Many have no defined contact centreMany have no defined contact centre• Few will commit to register although many Few will commit to register although many

will now pre-registerwill now pre-register• Supply chain complex with multiple Supply chain complex with multiple

supplierssuppliers• Some initially give only general responsesSome initially give only general responses• Too early to exchange use & fate Too early to exchange use & fate

information as no EU Guidanceinformation as no EU Guidance

Nalco will pre-register all our Nalco will pre-register all our chemicals and also no response chemicals and also no response chemicals & switch suppliers chemicals & switch suppliers

Downstream UsersDownstream UsersUse & FateUse & Fate

Downstream UsersDownstream UsersUse & FateUse & Fate

To be developed:To be developed:

• We will identify the use We will identify the use and fate of our products and fate of our products via Nalco Marketing and via Nalco Marketing and R&DR&D

• We will verify the outcome We will verify the outcome with our customerswith our customers

Downstream use: to be developed

Scheduled beginning 2008

Exposure PatternsExposure PatternsExposure PatternsExposure Patterns

ClosedSystem

Accidental

Soil

Waste

Air

Continuous

MatrixInclusion

Occasional

ConsumerProfessionalIndustrial

Non-Dispersive

Dispersive

Water

Oral InhalationDermal

Human

Environment

+ Use Category ? + Use Category ? + Use Category ? + Use Category ?

Industry Category

Use Category

Registration of1,000 T.Yr chemicals

Registration of100 T.Yr chemicals

Registration of1 T.Yr

chemicals

2010 2013 2018

2008 2009

Brief internal teams on programMake an inventory of all Nalco chemicalsDevelop 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 hiresModify MSDS template

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

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

Pre-register Nalco chemicals

REACH AheadREACH AheadREACH AheadREACH Ahead