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Article related to: REACH
REACH Review actions – status of our work
Back in 2018, the European Commission’s second REACH Review concluded that REACH was operating effectively, but also identified 16 actions where further work would be needed to strengthen chemicals management throughout Europe. We report on the latest status of work being done by the Agency to address these areas.
Needing to prioritise
“The increased demands to improve compliance and simplify authorisation, combined with an uncertain picture of our future resources, has meant we’ve had to set priorities for our work on the action plan. We’ve asked ourselves which areas we can pay the most attention to and have chosen those where we can make the most impact,” says Bjorn Hansen, ECHA’s Executive Director.
The rest of the 16 actions have, at least to some extent, needed to be temporarily placed on the backburner.
“Work needs to be done to catch up, and naturally a lot of the responsibility for this lies with us at ECHA. We’ll look at the other activities in greater detail as we finalise the 2020 Work Programme around November 2019. At that point, we will have a clearer picture of how we can divide the resources to tackle areas such as tracking substances in the supply chain, developing safety data sheets, encouraging substitution, improving restrictions and continuing to look at ways to offer better support to smaller companies,” he adds.
|Bjorn Hansen. |
|"More is demanded from us and to meet those demands we have made every effort to be as efficient as possible. But, we also need resources."|
Tracking substances of concern in the supply chain
The revision of the Waste Framework Directive has changed the scope of the action related to tracking substances of concern in the supply chain. Due to the new task ECHA has under the directive, the work has mainly focused on building the database that would contain information on substances of concern in articles. Here the Agency has been working with Member State authorities dealing with waste and REACH as well as industry to establish the information requirements.
Experience with implementing REACH so far has made it clear that one of the main challenges for companies is to know whether substances of concern are actually in their articles or not. “The work we’re doing aims to support industry to increase their knowledge on this. We know that through our work alone, we won’t get a full spectrum of data on SVHCs in articles, but through our discussions with stakeholders, there is at least now more awareness,” Mr Hansen states.
Enhancing safety data sheet quality
The addition of exposure scenarios to existing safety data sheets under REACH was a welcome step and has improved communication in the supply chain, making processes more transparent. But many companies, in particular small and medium-sized ones (SMEs), still find them too technical. The low quality of exposure scenarios has also proven to be an obstacle in providing safety information for mixtures.
“This is an issue of how we can support the continuous flow of information down the supply chain electronically, so that it’s synchronised with the transport and movement of the physical product. It is important that the information is understandable to the user and can also support compliance under other pieces of legislation dealing with occupational safety and health or the environment,” Mr Hansen says.
For this, an IT system with formats and conventions that would be acceptable for all actors in the supply chain is needed. Specific methodologies for confirming the safe use of mixtures through the information received from suppliers would also be required.
“We’re hosting a workshop from 23 to 24 September 2019 to discuss this matter with stakeholders and to understand the issues they feel need to be addressed. After this, we’ll have a better idea of the actions we can take and how much effort we’ll need to put into them,” he adds.
With work ongoing to simplify the authorisation process and improve the restriction procedure, ECHA has less staff resources available to promote substitution in 2020. One reason for this is that the staff working on substitution are the same as those managing the peak in authorisations and the continuously high workload on restrictions.
“At the moment, we concentrate on promoting substitution by implementing and improving the authorisation process. If we can ensure that applicants are aware of the uses and conditions being applied in their supply chains, this will also give them the information they need to identify concerns and potentially look at options for substitution as an alternative route. In early 2020, we aim to publicise ECHA’s updated substitution strategy that builds on the lessons learnt so far and those identified needs that ECHA can fulfil,” Mr Hansen explains.
On restrictions, there has been some progress not least with the development of the interface between REACH and Occupational Safety and Health (OSH) legislation. This interface will give ECHA’s Committee for Risk Assessment (RAC) experience and insight on how to improve the restriction procedure, particularly in relation to OSH.
Work is also being done to find ways to simplify the requirements for Member States submitting restriction dossiers. The aim is to increase their capacity for this work and encourage them to work together to prepare joint dossiers. The high workload with ECHA as the main producer of restrictions was never foreseen and needs to be addressed.
“There are currently 13 restrictions either under preparation or being discussed. For all of them, ECHA is either the dossier submitter or lending support to the Member States. We’re happy to continue while resources allow this, but we would also like to see Member States focusing more of their resources on restrictions,” Mr Hansen tells.
Another aspect is clarifying the basis upon which the precautionary principle is being applied. The work here involves RAC and ECHA’s Committee for Socio-economic Analysis (SEAC) ensuring that their opinions explicitly show when scientific data does not allow the risks and impacts to be completely evaluated.
“We are implementing the necessary considerations on uncertainty within our work so we can clearly communicate to the Commission if we believe there are cases where the precautionary principle should be considered. The microplastics restriction is one example of this as uncertainties in some parts of the assessment are higher than normal and, therefore, we will need to pay particular attention to this while the opinions are being developed,” he says.
It is essential for small and medium-sized companies (SMEs) to be able to understand and follow the work of the Agency. ECHA and Member States have been requested to step up efforts in this area.
“We do our utmost to consider and limit the impact our work has on SMEs. One example of this is our follow up to the EU Ombudsman’s draft guidelines on the use of official EU languages. Based on the principles, we are looking to see whether we need to amend our multilingual approach to better serve citizens,” Mr Hansen explains.
With the registration deadline over, there is a need for the Agency to recalibrate where it places its efforts. “To reiterate, more is demanded from us and to meet those demands we have made every effort to be as efficient as possible. But, we also need resources. Looking ahead at the next Multi-Annual Work Programme, the Commission has proposed for ECHA to be among a group of agencies that would have a budget cut in line with inflation. If this amounts to further staff cuts, we would face a threat to our ability to meet the demands placed on us. We should know more in 2020 once the new Commission has formed,” Mr Hansen concludes.
Did you know?
The 16 action points outlined in the REACH Review are:
Interview by Paul Trouth
Published on: 12 September 2019
Top image: © iStock.com/marchmeena29
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Committee for Risk Assessment:
25-28 November 2019 and
3-5 December 2019
Committee for Socio-Economic
26-28 November 2019 and
3-5 December 2019
Member State Committee:
9-11 December 2019
3-7 February 2020 (tentative)
Biocidal Products Committee:
10-11 December 2019
Management Board meeting:
12-13 December 2019