Latest EU Commission proposal for the REACH candidate list ‘undermines the credibility of the process’ – says lead industry
• Latest EU Commission proposal for candidate list is unilateral and hasty
• Large number of lead substances included for which authorisation is unlikely to be an effective risk management option
• ILA calls for increased transparency on the criteria for prioritising substances proposed for candidate listing
23 August 2012 - The International Lead Association (ILA) has expressed its dismay at the failure of the EU Commission to operate a transparent process for selection of Substances of Very High Concern (SVHC) to be listed on the REACH candidate list.
We believe that an analysis of the effectiveness of possible risk management options should be undertaken before substances are nominated for candidate listing. On behalf of the Lead REACH consortium, the ILA has been in discussion with the Commission for almost a year on the status of two lead compounds (lead monoxide and lead tetroxide) and believes that the inclusion of these, and a further 19 compounds not previously discussed, in the total of 38 newly nominated SVHC for the REACH candidate list is a unilateral and hasty proposal.
The ILA also questions why such a large number of lead compounds have been included in the latest proposal for additions to the candidate list.
Lead compounds represent a class of substances that are already heavily regulated in all stages of their lifecycle by existing EU Regulation. These regulations have been effective as lead emissions to air have reduced by more than 90 per cent in Europe during the period 1990-2009. This trend has been mirrored by significant reductions in blood lead levels in the general population and in occupationally exposed populations. The ILA therefore believes that identification of these substances on the candidate list is not proportionate and will not improve the quality or effectiveness of risk management or increase protection of human health and the environment.
“We are disappointed that the Commission chose not to consult with the ILA before it announced its proposal to include large numbers of lead compounds on the candidate list,” said Dr Andy Bush, ILA Managing Director.
Dr Bush added: “I can only presume that the late inclusion of these lead compounds was to meet the Commission’s target of 136 substances by the end of 2012.
“We believe that the stated objectives of REACH can only be achieved by a partnership between all parties concerned. Unfortunately this latest action brings into question the commitment of the Commission to engage with stakeholders in a fair and transparent way and undermines the credibility of the candidate listing process.”
The ILA and the Lead REACH Consortium are supportive of the aims of the REACH regulation to improve the protection of human health and the environment from the risks that can be posed by chemicals, while enhancing the competitiveness of the EU chemicals industry. This commitment is exemplified by the fact that the lead industry was one of the first commodities to provide Regulators with a comprehensive voluntary risk assessment at a cost of €4 million before REACH was introduced.
There are still mixed messages being delivered by the Commission and the European Chemicals Agency on the role of the candidate list and its relationship with selection of risk management options. In a letter to the Commission the ILA is urging it to clarify the situation, so that the aims of the REACH regulation are achieved in the quickest, most effective and targeted way possible, rather than concentrating on a target number of substances on the candidate list.
In the meantime the lead industry is preparing an official response to the consultation process that will be launched by ECHA on these substances and will submit its comments by the requested deadline.
Notes to editors:
On 17 August 2012 it was announced that the EU Commission has instructed the European Chemicals Agency (ECHA) to prepare Annex XV dossiers on an additional 38 Substances of Very High Concern (SVHC) with the intention that these substances are added to the REACH candidate list by the end of 2012. This will meet the Commission’s commitment to include 136 substances in the candidate list by the end of 2012.
The International Lead Association and Lead REACH Consortium do not dispute the conclusion that lead compounds having a harmonized classification in CLP Annex VI as CMR category 1A, meet the criteria for identification as REACH SVHC.
About the ILA
As secretariat to the Lead REACH Consortium, ILA Europe (a regional branch of the International Lead Association) is acting on behalf of the Lead Registrants for several lead substances.
REACH is a regulation of the European Union, adopted to improve the protection of human health and the environment from the risks that can be posed by chemicals, while enhancing the competitiveness of the EU chemicals industry.
The International Lea d Association is a membership body that supports companies involved in the mining, smelting, refining and recycling of lead. The ILA represents the producers of about 3 million tonnes of lead and almost two thirds of lead production in the western world.
With offices in the UK and USA the ILA provides a range of technical, scientific and communications support and is focused on all aspects of the industry’s safe production, use and recycling of lead.
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