As many people have been made aware from recent press releases the new EU chemicals legislation, REACH, has now come into force.
The legislation has many requirements of the chemicals industry, such as:
- Registering chemicals, including information on their production (or import) volumes
- Gathering toxicity data on those registered chemicals
- Gathering exposure data, or estimating exposure scenarios, of those registered chemicals
- Performing risk assessments on each chemical, based on the toxicity data and the exposure data
- Submitting the risk assessment to the EU, along with any suggested restrictions or control measures, for assessment
- Communicating those control measures to downstream users of the chemicals
This will happen in a staged process but will comfortably take around 15 – 20 years to run it’s course.
The first stage, registering chemicals, is now underway. As the costs involved are so high many manufacturers (or importers) may choose not to go through the registration process.
Once this is under way then those manufacturers (or importers) will need to know how their customers are using the chemicals so they can be sure to calculate the exposure to those chemicals correctly.
It will be some time before the first chemicals have their full toxicity and exposure packages evaluated and move onto the subsequent stage of communicating the results to their customers.
Blenders of chemicals, such as Selden, need to ensure that the chemicals we purchase are going through the registration phase (otherwise they will be withdrawn).
Selden can confirm this is taking place.
Purchasers of formulated products, such as Distributors, need to ensure that their suppliers are making adequate progress in dealing with this task. Since many chemicals are expected to be withdrawn from the market for economic reasons it is important to question key suppliers.
When exposure data is required it is not known how far down the supply chain manufacturers will need to go to determine how their chemicals are being used. This may involve Distributors or Users but is not of immediate concern.
When the data packages have been evaluated all Blenders, Distributors and Users of chemicals need to be prepared for controlling, analysing, and passing on a great deal of paperwork related to control measures. Logistically this will be difficult but is a number of years away.
More information regarding REACH is availble on the European Comission website