VOTOB supports the Dutch tank storage terminal operators with the safe, sustainable and transparent entrepreneurship. As such, VOTOB Members want to comply with the EU Chemicals Legislation, like REACH (REACH, 2006) and CLP (CLP, 2008).
The tank storage terminal operator (‘Terminal’) has a special position as logistical service provider in the supply chain of (petro)chemical products and it is not always clear for Parties involved who has what role and responsibility under REACH & CLP.
Therefore, a VOTOB Taskforce with representatives of the Dutch tank storage terminal operators and Jongerius Consult BV has prepared a draft VOTOB REACH Guidance document.
The objectives of the draft Guidance document was to provide a clear insight in the main activities of a Terminal and interactions with the main stakeholders. From this clear insight, the envisaged roles and responsibilities of the Terminal and Stakeholders under the European Chemicals Legislation (REACH & CLP) are described and some practical guidance is provided with a detailed REACH flow chart to support the Members in identifying their role(s) and responsibilities.
The draft guidance was provided with the recommendation to allow the VOTOB Members to use the guidance for a pilot period, consult other stakeholders and to collect comments and feedback for a further completion of the REACH Guidance.