10 ideas for improving chemicals risk management
Guy Thiran, Eurometaux Director General, puts forward the organisation's 10 ideas for improving chemicals management.
The European Chemicals Agency (Echa) has made risk management one of the key priorities in its 2019-23 programming strategy. That triggered us at Eurometaux to consider where improvements can be made to Europe’s chemicals risk management, in terms of its efficiency, consistency and integration.
Our sector – representing producers and recyclers of metals and other inorganic chemicals – is fully behind Echa’s commitment to optimise its risk management processes to achieve safer use of chemicals. We’re doing our part to continuously improve our knowledge on metals and reduce their impacts.
Overall, given most metals have some hazard properties, it’s essential that we properly control the exposure from metals and other chemicals, to make sure they can continue to be used safely in contribution to our shared climate and circular economy objectives.
After an in-depth reflection, our membership has developed a set of ten recommendations “for improving the integration of risk management in the EU’s legal framework”. Take a look at our ideas, which we’ll now be raising with authorities and other stakeholders.
Source: Eurometaux
1. Focus on what matters
Why? Risk management efforts should focus on well-identified and proportional concerns, in order to make the best use of resources and provide a solid foundation.
How? Authorities should develop a transparent prioritisation system, for selecting at the earliest stage which substances – or articles containing these substances – require risk management. This should also include an estimation of socioeconomic impacts and benefits.
2. Increase the information available for regulators to assess different risk management options (RMO)
Why? A large part of the information critical for a Risk Management Option assessment is not part of the registration file requirements.
How? Encourage industry to provide information relevant for RMO assessment in a timely fashion. Echa can facilitate this by including a dedicated reporting section in each registration dossier.
3. Optimise the efficiency of risk management by grouping substances when appropriate
Why? Appropriate grouping of substances for risk management, at an early stage, can increase the efficiency for all stakeholders.
How? During the prioritisation phase, authorities should invite industry to suggest their optimal “grouping proposal for risk management”. Grouping may be based, among other things, on chemical composition or use pattern.
4. Standardise a set of common risk management measures
Why? The risk management identification process would benefit from increased predictability and transparency, as well as the integration of wider EU environmental objectives.
How? Authorities and industry could develop a set of standard risk management scenarios/templates to be used for common situations. For example, substances whose exposure is confined to the workplace, or when there are large volumes of intermediates that are exempted from the scope of REACH authorisation. These scenarios should also aim to integrate other EU strategic priorities, for example the Circular Economy and Climate Change.
5. Involve all stakeholders more interactively when establishing risk management measures
Why? We have seen too many selected risk management measures being contested by stakeholders due to concerns with their efficiency and relevancy.
How? Authorities should re-evaluate the timing, format and content of their tools for stakeholder consultation and interaction. We would also support the addition of ‘hearing sessions’ to debate the scientific and technical challenges identified in the process for selecting risk management measures (in advance of RIME or Echa plenary sessions).
6. Reduce the need for extensive regulatory risk management “adoption procedures” where feasible
Why? Registrants should be encouraged to take more responsibility in the field of RMO assessments, in order to improve efficiency.
How? Industries to promote a regular update of the mapping of a substance’s uses in their registration dossiers and consider the relevancy of “uses advised against” as a risk management measure. To complement that, regulators should recognise the information provided as a relevant Risk Management option.
7. Better work sharing by industry on restriction development
Why? Authorities often undervalue restrictions as an efficient risk management option due to the high workload for their implementation.
How? Stakeholders should consider how industry and regulators can better share the burden of restrictions. For example – although this is not foreseen by the legal system – one option is to allow industry to make Annex XV proposals and allow authorities to focus their resources on the review of these proposals and on the implementation of the restrictions.
8. Promote sustainable and integrated risk management measures to prevent conflicts between EU environmental policies
Why? Care is needed to ensure that risk management measures do not hinder Europe’s other strategic goals, including the transition to a climate-neutral and circular economy. Rather, synergies should be maximised.
How? Industry and authorities should include a systemic assessment of the balance between relevant EU environmental policies (for example the Circular Economy) when defining the impact of risk management measures. This assessment should be made from the early RMO phase up to opinion forming in the Echa Committees.
9. Make better use of public consultations to collect data and evidence
Why? The different public consultations should be made more relevant, while staying resource efficient.
How? Authorities should promote an integrated public consultation system whereby stakeholders can provide technical, scientific and socioeconomic comments and evidence throughout a substance’s assessment – from priority setting up to the selection of the best risk management measure and committee processes. This would include the early identification of relevant alternatives.
10. Review past risk management measures and define areas for improvement
Why? We will only fully understand the effectiveness of risk management measures once they have been implemented. Reviewing past decisions will allow us to learn lessons and make improvements.
How? Implement a systemic assessment of past risk management measures and their efficiency. This would allow to determine whether the costs and benefits of their implementation met expectations, and whether adjustments are required for future decisions.
By launching these recommendations, Eurometaux shows its commitment for a continuous improvement of the risk management of hazardous chemicals in the EU. Moving forwards, we invite industry, regulators and other stakeholders to join us in an open and transparent debate on how to improve the efficiency of efficacy of Europe’s risk management measures system for the years to come. We’re looking forward to a good discussion.
The views expressed are those of the expert author and are not necessarily shared by Chemical Watch.