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Reducing REACH Risk Management

By Michael Wurzman

Recently, an equipment manufacturer voiced some concerns to me that you may also have. “REACH is so complicated,” he said. “It has so many nuances. How can I protect my company from being caught with an SVHC problem?  Where do I start?” My response to him was this: “Start by understanding the REACH implementation processes. If you understand those processes, you can proactively minimize the impact to your company.”

Stepping back for a moment, remember that REACH is designed to protect human health and the environment in the EU.  Therefore, the EU makes decisions on which substances to control based on the negative impacts that substances have.. Those decisions  may be biased toward those substances that present the greatest exposure risks in the EU.  In other words,  a known hazardous substance whose exposure is controlled can be less of a priority than a less hazardous substance with a major exposure risk.

Suggestions for which substances the EU should control come from a variety of sources. For instance, many of them come from EU non-governmental organizations. As an example, the Chemical Secretariat (ChemSec) publishes a “Substitute It Now”  (SIN) list that contains more than 600 substances.  Trade unions are another source. For instance, the European Trade Union Confederation (ETUC) is primarily concerned with exposures in the work place. In that regard,, the European Agency for Safety and Health at Work, which is the EU’s OSHA-equivalent, estimated that, in 2012, 50% of all occupational diseases1 are related to exposures from chemicals. The Agency also stated that cancer is now the main cause of “death by working conditions” in Europe.  More generally, any EU member state, organization or individual can push for a substance to be reviewed either for inclusion as an SVHC or for restrictions to be placed upon its use.

Whatever the source of potential substances to be controlled, the REACH process for evaluating those substances has several paths.  One path is the Community Rolling Action Plan (CoRAP), which is a three-year rolling plan for chemical review by member states to determine if more information about particular substances is needed. CoRAP’s list of substances under evaluation is dynamic and can be updated at any time.  The member states take assignments to review the submitted substance dossiers and to make a risk determination about potential risks and exposures.  After evaluation, the member states may recommend that a substance be included in either the Registry of Intentions for the SVHC Candidate list or the Registry of Intentions for the Restrictions list. The European Chemicals Agency (ECHA) can also review a substance dossier, and, if warranted, push for the substance to be  included in either of these lists as well.

Effectively, these two Registry of Intentions lists are an “early-warning system” for our companies. They indicate the likely next substances we will need to document and report upon. Therefore, by tracking the substances on these lists, we can proactively evaluate what actions we may need to reduce our substance-related risks. For example: we have long design cycles in our industry. If we wait until a substance is added to the Candidate list, we have only 6 months to report to our customers its presence in our products - hardly enough time to collect data from our deep supply chains. However, if we have used the early-warning system lists well, we will likely have enough lead-time to alter our designs.

Bottom line: protecting our companies necessitates understanding REACH’s processes; tracking the “early-warning system” lists; systematically collecting information on substances we use and that are in our products; and making sure that – well in advance - our design teams and supply chains are aware of REACH’s substance-documentation requirements.

-1 Occupational diseases are classified according to “diagnosis” and “cause” in the following groups: Hearing loss, Repetitive strain injury, Allergic respiratory diseases, Skin diseases, Asbestos-induced diseases and Others.

 

Article Library

  • 2017 IMDS and Chemical Reporting Summit
  • Article 33 obligations under REACH; The law of unintended consequences…or were they intentional?
  • Reducing REACH Risk Management
  • You Can't Go it Alone
  • The REACH Data Dilemma: Part 2
  • The REACH Data Dilemma: Part 1
  • The Case for Training
  • The Importer-of- Record and REACH Obligations
  • The “H” Factor