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October 14, 2022 is an important day for the international transport of dangerous chemical goods. On this day, the latest revision of the EU Regulation on Registration, Evaluation, Authorization and Restriction of Chemicals enters into force. This regulation is known under the label REACH.
REACH obliges all actors involved in the transport of chemicals to ensure that these chemicals are used safely at all times. For this purpose, extensive information must be submitted on all chemicals. Chemicals may not be placed on the market without registration. This information is continuously supplemented and monitored in the logistics process – all the way to the consumer, who has a right to information about the chemicals. The data collection contains not only information on the respective substances, but also on dangerous potentials and possible substitutes.
The changes, which come into force in October, are to be interpreted as part of a fundamental reform strategy of the European Union. The aim of the so-called European Green Deal is to change the production and trade of chemicals by 2050 in such a way that human beings and the environment are harmed as little as possible.
As of October 14, numerous additional disclosures must be submitted with REACH applications. These relate in particular to the ecotoxicity of the substances. Here, additional evidence of ecological safety may be required for some chemicals. It is imperative that anyone placing chemicals on the market familiarize themselves with the new regulations well in advance of the October 14, 2022 deadline. The regulation itself can be viewed online at the EU. However, interested companies can also find extensive information at the European Chemical Industry Council(Cefic), the German Chemical Industry Association(VCI) or other national chemical associations.
We asked around at the European Chemical Industry Council to find out first-hand what we can expect in terms of REACH in the coming years.
One of the most important trends, Cefic believes, will be the replacement of animal testing with alternative safety assessment methods. Animal testing is becoming less and less necessary for the toxicological evaluation of chemicals, he said.
On the other hand, more and more new chemicals are being included in the REACH process. This would also tend to necessitate ever new additional risk potential analyses. Polymers are one example of this. These have so far been exempt from the REACH regulations. This will probably change soon. Cefic assumes that a simplified risk assessment applies here, as these substances are generally largely harmless from an ecological point of view. There are also between 70,000 and 400,000 different polymers on the market today. Distinguishing between those that are of concern and require registration and further regulatory action and those that are of little concern will therefore be key to the successful implementation of this new policy measure. For example, Cefic calls for substances to be grouped into substance classes. This applies not only to polymers, but also to other chemicals.
In this way, approval processes could always be carried out for entire product classes at once. After all, the aim was not only to save costs for the risk assessment of non-dangerous substances, but also to reduce the number of animal experiments required for this purpose. An important argument that can be well communicated socially.
Closer integration of REACH, i.e. risk management in the transport and trade of chemicals, with the various workplace and occupational safety regulations is also on the EU agenda. In a public discussion at Cefic, for example, Ignacio Doreste, Senior Advisor at the European Trade Union Confederation (ETUC), called for more synergy between REACH and EU health and safety legislation to avoid duplication in the future. If the worker in the chemical company is safe, so is the worker in the logistics company and ultimately the end consumer. If the workplace in the manufacturing company is safe and green, then – at least in tendency – our environment remains so as well.
The German VCI points out in a statement on current EU REACH plans points out that optimization of supply chain communication is urgently needed: “Supply chain communication can be simplified by using experiences of the creators and users of extended safety data sheets in the context of digitalization to align best practices. Harmonized electronic forms must be compatible with systems already established in companies.” Especially in the area of warehouse logistics, the players involved will benefit in the future from the digitalization and standardization of safety data sheets.
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