Ways to influence in the SVHC listing process

Dear Readers,
We had a webinar last week about Risk Management Option Analysis (RMOAs), which is one of the new initiatives in SVHC and authorization process (the other new initiative is the public SEA consultation by Commission). I would like to thank you, we have gotten a lot of feedback and questions about what kind of impacts we are expecting from these new openings.

Indeed, there is an overhaul on going. A few conclusions about how we see the SVHC process in the upcoming years.

Q1: Are the new initiatives leading to fewer substances in the future SVHC process? The answer is NO. The statement from authorities is very clear. Until 2020 all known SVHC substances (around 440) should go thru the process. This is expressed in “Roadmap for SVHC Identification and Implementation of REACH Risk Management Measures” and also in the latest CORAP (Community Rolling action plan covering years 2015-2017). During the upcoming years the goal is to evaluate 134 substances.

Q2. So, if these new openings are not leading to fewer substances, what is the real impact? In cases that we have currently ongoing at ECHA, we already see the change. The process is much more careful, it is clear that a lot of more emphasis is put on efficiency of the selected risk management option. In the past we have seen cases where the use of OEL (Occupational Exposure Limits) had been a more efficient tool. This applies to cases where the replacement is in short term almost impossible and authorization application is not contributing to lower risk at downstream users in short term and also the contribution to R & D is dubious. A second big change is that the process is more transparent and industries have a real opportunity to affect the outcome.
In nutshell, inclusion to Annex XIV is no longer a given outcome, we expect wider scale of RMOs, e.g. exempted uses, use of OELs, restrictions etc. However, there is one requirement if we want that this happen. Industry must take this change to contribute already in earlier phases of the process, industry “owns” both the knowledge and data.

If you would like to hear more about how we can help your company to get the best outcome for its business, please do not hesitate in contact me at: lasse.musakka@reachlaw.fi

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