An Insider Perspective on REACH
Since it began eight years ago, REACH has been the focal point of many product stewardship activities. Although the reasons for enacting REACH are positive, the implementation has been met with challenges, said Christel Musset before a gathering of product stewards.
Musset, who serves as director of registration for the European Chemicals Agency (ECHA), shared her perspective on the evolution of REACH during a talk at Stewardship 2015. “REACH was not invented to annoy companies,” she said to laughter from the audience. From a global perspective, the objective has been to minimize adverse effects on human health and the environment from chemicals. REACH and CLP (GHS implementation) are the vehicles for doing that. The agency operates according to a key principle—that industry is responsible for demonstrating that substances are used safely throughout the supply chain.
REACH was designed in part to improve collective knowledge on properties and uses of chemicals, along with better communication in the supply chain. In relation to the mission of product stewardship, “I think we are very close actually,” said Musset.
If the system worked perfectly, regulators would be unnecessary. Product stewardship alone would ensure a level of risk management regarding substance of concerns. “The system does not work fully properly, which is why we’re here,” said Musset. Once information is collected by industry and the classification is done, then the authorities are there to make sure the substances of concern are regulated.
A successful outcome of REACH is the knowledge it has generated. After eight years, ECHA has received 50,000 registrations covering more than 13,000 chemicals, with approximately 2 million summaries on properties and effects. The information is publicly available, so authorities and others worldwide can review the information, said Musset.
Not that there haven’t been challenges. A recent review of REACH acknowledged that improvements were possible in implementation, including the quality of the dossier information. Also, SMEs find compliance a burden, said Musset, so an ongoing focus will be placed on simplifying guidance for those companies and creating user-friendly IT tools.
Communication across the supply chain is also an issue. “The more you go down the supply chain, the more difficult it is to find information on how the substance is being used,” she said.
Musset outlined some of the steps ECHA is taking as REACH evolves. She noted that resources directed toward substances with the biggest impact on health and the environment. “We changed our mindset. Instead of focusing on everything…we’re prioritizing,” she said.
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