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Phasing out dangerous substances – how can we speed up?
REACH is one of the main reasons why companies identify hazardous substances and find safer alternatives to substances of very high concern in the EU. But, how can we speed that process up? By devoting more time and money to it and by coordinating our efforts. It is also important to bring authorities, researchers and industry together. ECHA Newsletter spoke with Dr Joel Tickner and Ms Molly Jacobs about the main findings of their study on substitution.
“There is a clear interest in substitution in Europe. With greater capacity and enhanced collaboration, there are great opportunities to increase substitution,” says Dr Joel Tickner from the University of Massachusetts, Lowell Centre for Sustainable Production. Dr Tickner and Ms Jacobs have carried out a study for ECHA, to explore how finding safer alternatives could be accelerated and what the main obstacles are. The study finds that there is a clear pressure for substitution in Europe and that the REACH Regulation is a dominant driver for it. This differs clearly from the situation in the United States where substitution is mainly a market driven activity, with less pressure from authorities.
What's holding us back?
“Despite these pressures, and the inherent responsibility to substitute with safer alternatives, the resources and capacity are not there in authorities and in industry to support the actual process of substitution,” Dr Tickner points out. Many Member States are active in investigating safer chemicals but they do not always share information with each other. Therefore, he is calling for better coordination of the ongoing substitution programmes.
“Given the limited resources, there is no reason why similar efforts should be undertaken by multiple authorities. So, collaboration – between authorities, through the supply chain and with stakeholders – is critical to developing expertise, sharing knowledge and ensuring successful substitution activities,” Dr Tickner states.
Lack of research funding for innovation
Innovation requires research and research requires money. Therefore, the funding of research becomes a key issue. “In our survey and interviews, we often heard about the need for research funds to really support innovation and identify alternatives,” Ms Jacobs says. There are several research funding programmes that could support identifying alternatives but they are not always easy to find or linked to regulatory priorities. “The next step has to be to map what the innovation funds are for. Many are targeted in a very specific direction and with a quick look, substitution is not mentioned as a grant priority. It does not mean that if they received a proposal related to substitution that it would be rejected but these should be explored further,” Ms Jacobs explains.
According to Dr Tickner, a significant portion of the materials-related research money from the European Commission is currently going to the circular economy. This is an important area of research and identifying safer alternatives would fit perfectly into this discussion. “If you deal with a dangerous chemical and it is in a circular economy, this means that you will just keep circulating it and bringing it back around. That is not a good solution.”
In addition to funding, it is important to bring together the researchers and the companies who are looking for safer alternatives. “We have identified a large and growing research base in sustainable and green chemistry,” Ms Jacobs explains and continues, “however, researchers are often completely disconnected to the alternatives development needs of industry. To make this link also requires coordination between industry and academic research institutes.” This is something that ECHA could help with. Even though finding funds is not a task for regulatory agencies, they are needed to bring the different actors together.
Improving technical feasibility and alternatives assessment
One of the biggest risks in substitution is that the alternative substance may not work out as hoped. Sometimes the uncertainty around the feasibility of the safer alternative can stop the substitution. “It is important to find ways to enhance collaboration around technical feasibility, for example, through industry sector groups,” Dr Tickner emphasises.
He gives an example of the collaboration in Massachusetts between the university and small companies using problematic solvents in degreasing. Regulations and liability concerns were driving the companies to consider changing from these hazardous substances to safer alternatives. But the companies were hesitant to do so because of a lack of resources to test the alternative and concerns about reduced performance. To help out, the university set up a laboratory to help companies to do proper performance testing, to eliminate the technical risk of substitution.
In addition to resource challenges, when assessing the technical feasibility of an alternative, there is often a lack of information in supply chains due to confidentiality issues. This is an example of a bottle neck that could be unblocked by better collaboration, exchange of knowledge and more open communication.
Since the assessment of alternatives is crucial to identify safer substances and assess their implementation, the staff working on this have to be properly trained to ensure quality. “Both the applications for authorisation and restriction proposals that we have reviewed vary significantly in quality,” Dr Tickner says and continues, “there is a need for training and education and this applies to industry and industry groups but also for the staff in Member States and in ECHA and its committees, so that they can understand what makes a high quality assessment.”
“Time is critical”
According to Dr Tickner, even the simplest substitution can take one to two years to implement. Therefore, his message to companies is to start evaluating alternatives as early as possible. “Supply chain and sectoral collaboration is critical in this. The earlier you start looking for alternatives and working with research institutes, your own trade institutes and the government authorities, the better the position you will be in to substitute.”
Also, many EU Member States have their own funding programmes.
In January 2016, ECHA commissioned a study to look at the process of substituting dangerous chemicals in the EU. The aim of the study was to find practical ways of promoting innovation and substitution in the EU. The study was led by Dr Joel Tickner, Director and Associate Professor of Environmental Health, and Ms Molly Jacobs, Senior Research Associate and Project Manager from the University of Massachusetts, Lowell Centre for Sustainable Production. Dr Tickner and Ms Jacobs carried out surveys and interviews with representatives of the Member State competent authorities, non-governmental organisations, industry and research centres.
The report Improving the Identification, Evaluation, Adoption and Development of Safer Alternatives: Needs and Opportunities to Enhance Substitution Efforts within the Context of REACH was published on 5 September.
In the coming months, ECHA will be acting on the recommendations from this report.
Interview by Päivi Jokiniemi and Julia Sierra
Top images: left: Molly Jacobs, right: Joel Tickner. Copyright: University of Massachusetts Lowell
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