Chair:Jean-Philippe MontfortPartner, Mayer Brown
Coffee & Registration
- Session 1: Overviews and possible future developments
The outcome of the REFIT process on authorisationAnna BorrasEuropean Commission
The SVHC Roadmap report and perspectives for the future
Sylvie LemoineExecutive Director Product Stewardship, Cefic
- The chemical industry's perspective on the SVHC Roadmap and associated implementation activities
- Enhancements to the Risk Management Options Analysis approach and its practical implementation
- Recently observed trends in regulating the most hazardous substances.
Risk management options analysis: How to ensure the best choice
Richard LuitSenior Policy Advisor Chemicals Management, RIVM
- Thoughts on how to define “best choice” from various perspectives
- Available RMOs, SVHC identification may be part of most - but not necessarily
- Key principles used by NL CA to arrive at most appropriate RMO to manage substances of concern taking into account information on hazard/exposure/risk and socio-economic aspects
The streamlining of authorisation: Efficiency versus leniencyAlice BernardLawyer (Juriste), Client Earth
Making upstream applications work
Sue BullockPrincipal, Ramboll
- Upstream applications for authorisation have challenged both industry and the authorities in recent years, drawing out both critics and defenders.
- Upstream authorisation are clearly foreseen under REACH and are, moreover, a critical mechanism for several industry sectors, such as aerospace.
- While upstream approaches in principle should support harmonized and efficient regulation, such applications have been slow to progress and so deliver this promise.
- As decisions near for upstream applications submitted several years ago, it’s timely to reflect on the learnings so far and consider the possible futures for this process.
- Session 2: Substitution as a risk management question
How can we ensure that the right information gets fed into the public consultation to inform the authorisation process
Frida HokSenior Policy Advisor, ChemSec
- Authorisation process is to promote the replacement of SVHCs
- To make an accurate alternative assessment relevant, information from potential alternative providers and from other companies in the same field need to be taken into account
- Specifically the public consultation is not fit for purpose to gather all the necessary information to perform an accurate alternative assessment
- REACH authorisation process should reward the frontrunners instead of the laggards
Substitution as an RMM option: Reality and challengesMatti VainioHead of Unit, Risk Management Implementation, ECHA
Changes of Annex XIV listing: what is the future of promoting substitution?
- Session 3: Specific suggestions to improve efficiency of risk management
Use of Article 58(2) of REACH - exemptions for risks covered by other legislation
Steve BinksDirector Regulatory Affairs, International Lead Association
- What conditions must be met before a REACH Article 58(2) exemption from authorisation can be considered?
- Overview of available case law and legislative history
- Challenges for future successful Article 58(2) exemption applications
Substances and mixtures containing SVHC minor constituents and impurities
France CaponEuropean Precious Metals Federation (EPMF)
- SVHC Risk Management so far focused on registered substance or main constituent
- Especially materials resulting from recycling contain minor constituents/impurities and may require Risk Management consideration
- Caracal provided several options but due to recent challenge clarification and legal certainty are now required
Occupational Exposure Limits (OELs) as Risk Management Options (RMO) for substances at the workplace: Who does what?
Tiina SantonenChief Specialist, Finnish Institute of Occupational Health
- Pros and cons of authorisation in comparison to OEL system
- When should OELs be considered as the best option?
- Examples of recent cases.
Sustainable substitution in the metals sector
Hugo WaeterschootREACH Advisor, Eurometaux
- For the metals and inorganics sector sustainable substitution is linked to specific properties of metals
- Stepwise approach to assessing if the replacement of SVHC is technically and economically feasible from a combined perspective of Chemicals Management (REACH), Circular Economy and other EU policy objectives
- How do the different suggestions fit into the overall picture in the longer term?
- Despite extensive efforts from the side of regulators, so far authorisation hasn’t stimulated much substitution beyond what the market was driving for anyway. Does this mean that the authorisation scheme isn’t fit for this aim, or that the EU scale isn’t broad enough to handle substitution in a globalising world?
- What is the main aspect that needs to be improved to stimulate substitution for Annex XIV listed substances?
- What are the tools/suggestions needed to achieve the targets?
End of conference