impacts of the european commission’s reach proposal on risk assessment joel a. tickner, scd and...

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Impacts of the European Commission’s REACH Proposal on Risk Assessment Joel A. Tickner, ScD and Ken Geiser, PhD Lowell Center for Sustainable Production University of Massachusetts Lowell [email protected]

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Page 1: Impacts of the European Commission’s REACH Proposal on Risk Assessment Joel A. Tickner, ScD and Ken Geiser, PhD Lowell Center for Sustainable Production

Impacts of the European Commission’s REACH Proposal

on Risk Assessment

Impacts of the European Commission’s REACH Proposal

on Risk Assessment

Joel A. Tickner, ScD and Ken Geiser, PhD

Lowell Center for Sustainable Production

University of Massachusetts Lowell

[email protected]

Joel A. Tickner, ScD and Ken Geiser, PhD

Lowell Center for Sustainable Production

University of Massachusetts Lowell

[email protected]

Page 2: Impacts of the European Commission’s REACH Proposal on Risk Assessment Joel A. Tickner, ScD and Ken Geiser, PhD Lowell Center for Sustainable Production

Europe and the US – Similar ProblemsEurope and the US – Similar Problems

Lack of toxicity/exposure information on chemicals in commerce

Unequal treatment of new/existing chemicals Slow chemical by chemical risk assessment

process, burden on government Lack of incentives to stimulate development

and implementation of safer substitutes Increasing evidence of health effects Lack of integrated and comprehensive

approach to chemicals management

Lack of toxicity/exposure information on chemicals in commerce

Unequal treatment of new/existing chemicals Slow chemical by chemical risk assessment

process, burden on government Lack of incentives to stimulate development

and implementation of safer substitutes Increasing evidence of health effects Lack of integrated and comprehensive

approach to chemicals management

Page 3: Impacts of the European Commission’s REACH Proposal on Risk Assessment Joel A. Tickner, ScD and Ken Geiser, PhD Lowell Center for Sustainable Production

The REACH ProposalThe REACH Proposal

In February of 2001, the European Commission issued a White Paper on the Future of Chemicals that proposed a major new policy called REACH

REACH: • Registration

• Evaluation

• Authorization of

• CHemicals

In February of 2001, the European Commission issued a White Paper on the Future of Chemicals that proposed a major new policy called REACH

REACH: • Registration

• Evaluation

• Authorization of

• CHemicals

Page 4: Impacts of the European Commission’s REACH Proposal on Risk Assessment Joel A. Tickner, ScD and Ken Geiser, PhD Lowell Center for Sustainable Production

The REACH Proposal The REACH Proposal

A duty of care on chemical producers, users, and importers for studying risks and safety

A European-wide approach to chemicals policy – protect internal market

Substitution of chemicals of very high concern - innovation in safer chemicals

Bridge knowledge gap between new and existing chemicals – develop information on all chemicals.

Reduction in animal testing Promotion of a non-toxic environment – the

“generational goal”

A duty of care on chemical producers, users, and importers for studying risks and safety

A European-wide approach to chemicals policy – protect internal market

Substitution of chemicals of very high concern - innovation in safer chemicals

Bridge knowledge gap between new and existing chemicals – develop information on all chemicals.

Reduction in animal testing Promotion of a non-toxic environment – the

“generational goal”

Page 5: Impacts of the European Commission’s REACH Proposal on Risk Assessment Joel A. Tickner, ScD and Ken Geiser, PhD Lowell Center for Sustainable Production

Components of REACHComponents of REACH

Registration – testing, data collection, and assessment of all chemicals and supply chain information

Evaluation of risks of chemicals used in greatest quantity and of highest concern

Accelerated risk management for chemicals of concern

Authorization for substances of highest concern. Establishment of a new central administrative

agency

Registration – testing, data collection, and assessment of all chemicals and supply chain information

Evaluation of risks of chemicals used in greatest quantity and of highest concern

Accelerated risk management for chemicals of concern

Authorization for substances of highest concern. Establishment of a new central administrative

agency

Page 6: Impacts of the European Commission’s REACH Proposal on Risk Assessment Joel A. Tickner, ScD and Ken Geiser, PhD Lowell Center for Sustainable Production

RegistrationRegistration

Essentially a notification process All producers and importers of substances

produced over 1m ton/year (about 30,000 substances)

Phased in over 3 yrs, 6 yrs, and 11 yrs Pre-registration, consortia establishment Exemptions for R&D, intermediates, polymers,

others Current New Chemicals are considered

registered Requirement to submit new data

Essentially a notification process All producers and importers of substances

produced over 1m ton/year (about 30,000 substances)

Phased in over 3 yrs, 6 yrs, and 11 yrs Pre-registration, consortia establishment Exemptions for R&D, intermediates, polymers,

others Current New Chemicals are considered

registered Requirement to submit new data

Page 7: Impacts of the European Commission’s REACH Proposal on Risk Assessment Joel A. Tickner, ScD and Ken Geiser, PhD Lowell Center for Sustainable Production

Registration requirementsRegistration requirements

Base information – identity, information on manufacture and uses, proposed classification/labeling,

Chemical safety assessment/guidance on safe use (over 10 tons) – risk assessment for all identified uses

Additional tiered testing/information – requirements – flexibility

Requirement to consult database/authorities before testing

Required data sharing/compensation – Substance Information Exchange Forum

Base information – identity, information on manufacture and uses, proposed classification/labeling,

Chemical safety assessment/guidance on safe use (over 10 tons) – risk assessment for all identified uses

Additional tiered testing/information – requirements – flexibility

Requirement to consult database/authorities before testing

Required data sharing/compensation – Substance Information Exchange Forum

Page 8: Impacts of the European Commission’s REACH Proposal on Risk Assessment Joel A. Tickner, ScD and Ken Geiser, PhD Lowell Center for Sustainable Production

EvaluationEvaluation

Essentially a risk screening process Two types: standard and priority

• Standard: minimize duplicative testing for high production volume substances

• Priority: review of registration to identify additional information needs (focus on high volume/high concern plus intermediates and randomly selected substances)

Requirement to consult other Member States before requiring additional testing

Can lead to risk management recommendations.

Essentially a risk screening process Two types: standard and priority

• Standard: minimize duplicative testing for high production volume substances

• Priority: review of registration to identify additional information needs (focus on high volume/high concern plus intermediates and randomly selected substances)

Requirement to consult other Member States before requiring additional testing

Can lead to risk management recommendations.

Page 9: Impacts of the European Commission’s REACH Proposal on Risk Assessment Joel A. Tickner, ScD and Ken Geiser, PhD Lowell Center for Sustainable Production

AuthorizationAuthorization

Essentially a use restrictions process Applies to chemicals of very high concern –

CMRs 1&2, PBTs, VPVBs, and other high concern substances

Requirement to request authorization for high concern chemicals – timelines (includes use and incorporation into articles)

Consideration of socio-economic benefits, alternatives, controls in place (safe use)

Can be subject to conditions/time limited Community/Member State authorizations

Essentially a use restrictions process Applies to chemicals of very high concern –

CMRs 1&2, PBTs, VPVBs, and other high concern substances

Requirement to request authorization for high concern chemicals – timelines (includes use and incorporation into articles)

Consideration of socio-economic benefits, alternatives, controls in place (safe use)

Can be subject to conditions/time limited Community/Member State authorizations

Page 10: Impacts of the European Commission’s REACH Proposal on Risk Assessment Joel A. Tickner, ScD and Ken Geiser, PhD Lowell Center for Sustainable Production

Restrictions processRestrictions process

A “safety net” – for Community wide protection Member State proposal for restriction Preparation of risk assessment and socio-

economic assessment Commission decision Can specify types of restrictions Time limited process

A “safety net” – for Community wide protection Member State proposal for restriction Preparation of risk assessment and socio-

economic assessment Commission decision Can specify types of restrictions Time limited process

Page 11: Impacts of the European Commission’s REACH Proposal on Risk Assessment Joel A. Tickner, ScD and Ken Geiser, PhD Lowell Center for Sustainable Production

Role of new chemicals agencyRole of new chemicals agency

Database on chemicals under registration/ authorization

Completeness check of registration dossiers Risk assessment/socio-economic analysis for

Community authorizations Risk and socio-economic analysis for

restrictions Forum for exchange of information on

enforcement Maintenance of much expertise in Member

States

Database on chemicals under registration/ authorization

Completeness check of registration dossiers Risk assessment/socio-economic analysis for

Community authorizations Risk and socio-economic analysis for

restrictions Forum for exchange of information on

enforcement Maintenance of much expertise in Member

States

Page 12: Impacts of the European Commission’s REACH Proposal on Risk Assessment Joel A. Tickner, ScD and Ken Geiser, PhD Lowell Center for Sustainable Production

EU Legislative ProcessEU Legislative Process

White Paper Draft legislation Comment Period Final Commission proposal First Reading Parliament/Council Second Reading Council/Parliament (time

limited) with Commission debate Conciliation (time limited)

White Paper Draft legislation Comment Period Final Commission proposal First Reading Parliament/Council Second Reading Council/Parliament (time

limited) with Commission debate Conciliation (time limited)

Page 13: Impacts of the European Commission’s REACH Proposal on Risk Assessment Joel A. Tickner, ScD and Ken Geiser, PhD Lowell Center for Sustainable Production

Impacts of REACH on Risk Assessment – new data and initial burden on industryImpacts of REACH on Risk Assessment – new data and initial burden on industry

Burden on industry to come up with test data or equivalent information• Availability of test data for most existing

substances

• Ability to use surrogates (QSAR, category approach, alternatives) if satisfactory

Burden on industry to provide risk assessment and risk management recommendations for all identified uses according to guidance

New supply chain use and exposure data

Burden on industry to come up with test data or equivalent information• Availability of test data for most existing

substances

• Ability to use surrogates (QSAR, category approach, alternatives) if satisfactory

Burden on industry to provide risk assessment and risk management recommendations for all identified uses according to guidance

New supply chain use and exposure data

Page 14: Impacts of the European Commission’s REACH Proposal on Risk Assessment Joel A. Tickner, ScD and Ken Geiser, PhD Lowell Center for Sustainable Production

New government risk assessment responsibilitiesNew government risk assessment responsibilities Development of good IT system for collecting,

analyzing, and public access to data• Data on some 11,000 chemicals over 11 years

• Protecting CBI

Spot checks of dossiers for completeness Member States perform evaluation of risk

assessments for certain higher concern substances (high volume, toxicity concerns)• For additional data/risk assessment needs

• For risk management recommendations

Determination of new chemicals of concern for which registration is warranted – intermediates

Development of good IT system for collecting, analyzing, and public access to data• Data on some 11,000 chemicals over 11 years

• Protecting CBI

Spot checks of dossiers for completeness Member States perform evaluation of risk

assessments for certain higher concern substances (high volume, toxicity concerns)• For additional data/risk assessment needs

• For risk management recommendations

Determination of new chemicals of concern for which registration is warranted – intermediates

Page 15: Impacts of the European Commission’s REACH Proposal on Risk Assessment Joel A. Tickner, ScD and Ken Geiser, PhD Lowell Center for Sustainable Production

Need for rapid screening and assessment toolsNeed for rapid screening and assessment tools Need for tools to rapidly characterize chemical

hazards, exposures and risks• Traditional risk assessment methods won’t be quick

enough

Need effective prioritization schemes• Need indicators of which chemicals seem to be of higher

concern• One option is establishment of list of “chemical

categories”• Opportunities to reduce registrations by encouraging

non-registration of chemicals of concern.

Need tools that can be given to industry to help then internalize good assessment practices

Need for tools to rapidly characterize chemical hazards, exposures and risks• Traditional risk assessment methods won’t be quick

enough

Need effective prioritization schemes• Need indicators of which chemicals seem to be of higher

concern• One option is establishment of list of “chemical

categories”• Opportunities to reduce registrations by encouraging

non-registration of chemicals of concern.

Need tools that can be given to industry to help then internalize good assessment practices

Page 16: Impacts of the European Commission’s REACH Proposal on Risk Assessment Joel A. Tickner, ScD and Ken Geiser, PhD Lowell Center for Sustainable Production

Rapid chemicals review under TSCA Section 5Rapid chemicals review under TSCA Section 5

Multi-disciplinary, multi-step hazard and risk review throughout lifecycle

Rapid chemical assessment using available data (SAR, surrogates, etc.)

Conservative assumptions in face of data gaps Build on database/experience of 30,000 new

chemicals analyzed

Multi-disciplinary, multi-step hazard and risk review throughout lifecycle

Rapid chemical assessment using available data (SAR, surrogates, etc.)

Conservative assumptions in face of data gaps Build on database/experience of 30,000 new

chemicals analyzed

Page 17: Impacts of the European Commission’s REACH Proposal on Risk Assessment Joel A. Tickner, ScD and Ken Geiser, PhD Lowell Center for Sustainable Production

Information Needs in REACHInformation Needs in REACH Need for good process/facility/supply chain level

materials accounting information• Materials not efficiently managed (what you can’t

measure you can’t manage)

• Identifies opportunities for greater efficiency and supply chain uses and places for exposure reduction and substitution

Need good metrics to measure progress Need good information on alternatives to problem

substances• Market pressures from good information on

alternatives

Need for good process/facility/supply chain level materials accounting information• Materials not efficiently managed (what you can’t

measure you can’t manage)

• Identifies opportunities for greater efficiency and supply chain uses and places for exposure reduction and substitution

Need good metrics to measure progress Need good information on alternatives to problem

substances• Market pressures from good information on

alternatives

Page 18: Impacts of the European Commission’s REACH Proposal on Risk Assessment Joel A. Tickner, ScD and Ken Geiser, PhD Lowell Center for Sustainable Production

The big risk assessment challenge in REACH – alternatives assessmentThe big risk assessment challenge in REACH – alternatives assessment Chemical changes mean process changes

• Potential for risk trade-offs (community, occupational)

• Defeats goals of REACH if companies switch to other problem substances

No clear cut tools for comparative assessments• P2OASys – UMASS Lowell

• German, Swedish, OSPAR, Nordic Substitution methodologies

• University of TN Risk Ranking tool/CTSA method

• PBT Profiler

A challenge to develop procedures for substitution assessment

Chemical changes mean process changes• Potential for risk trade-offs (community,

occupational)

• Defeats goals of REACH if companies switch to other problem substances

No clear cut tools for comparative assessments• P2OASys – UMASS Lowell

• German, Swedish, OSPAR, Nordic Substitution methodologies

• University of TN Risk Ranking tool/CTSA method

• PBT Profiler

A challenge to develop procedures for substitution assessment

Page 19: Impacts of the European Commission’s REACH Proposal on Risk Assessment Joel A. Tickner, ScD and Ken Geiser, PhD Lowell Center for Sustainable Production

Goals of a substitution assessment methodGoals of a substitution assessment method

Compare toxicity, physical hazards and other trade-offs at process and lifecycle levels

Identify key criteria for avoidance (ie PBT) Allow flexibility to adapt to particular chemical,

use Allow use of expert judgment

• Number scores are easy but hide information

Be simple and clear enough so that firms and regulators can use

Outline a clear process/guidelines for “substitution thinking”

Compare toxicity, physical hazards and other trade-offs at process and lifecycle levels

Identify key criteria for avoidance (ie PBT) Allow flexibility to adapt to particular chemical,

use Allow use of expert judgment

• Number scores are easy but hide information

Be simple and clear enough so that firms and regulators can use

Outline a clear process/guidelines for “substitution thinking”

Page 20: Impacts of the European Commission’s REACH Proposal on Risk Assessment Joel A. Tickner, ScD and Ken Geiser, PhD Lowell Center for Sustainable Production
Page 21: Impacts of the European Commission’s REACH Proposal on Risk Assessment Joel A. Tickner, ScD and Ken Geiser, PhD Lowell Center for Sustainable Production

A possible process for substitution assessmentA possible process for substitution assessment

Problem Identification Identification and development of a range of

alternatives (chemical, non-chemical) Identification of the consequences of the

alternatives Comparison of the alternatives Decision Implementation Evaluation of the results/reevaluation

Problem Identification Identification and development of a range of

alternatives (chemical, non-chemical) Identification of the consequences of the

alternatives Comparison of the alternatives Decision Implementation Evaluation of the results/reevaluation

Page 22: Impacts of the European Commission’s REACH Proposal on Risk Assessment Joel A. Tickner, ScD and Ken Geiser, PhD Lowell Center for Sustainable Production

TSCA Section 5: Guidance Towards Safer ChemicalsTSCA Section 5: Guidance Towards Safer Chemicals

Attempt to get safer chemicals to market to replace existing problem ones

Pre-manufacture pollution prevention review of substances and syntheses

Green chemistry initiatives Informal discussion with manufacturers Agency going from gatekeeper to encouraging

safer chemicals and processes

Attempt to get safer chemicals to market to replace existing problem ones

Pre-manufacture pollution prevention review of substances and syntheses

Green chemistry initiatives Informal discussion with manufacturers Agency going from gatekeeper to encouraging

safer chemicals and processes

Page 23: Impacts of the European Commission’s REACH Proposal on Risk Assessment Joel A. Tickner, ScD and Ken Geiser, PhD Lowell Center for Sustainable Production

ConclusionsConclusions

REACH will require development of new risk assessment tools• For rapid assessment

• For alternatives assessment

• Without these will have collection of data

REACH will require development of clear guidance on how to assess chemicals, substitutes, and trade-offs

REACH will require tools to understand risk reduction activities/progress towards goals

To be more effective, REACH needs to include more data on process level use and exposure

REACH will require development of new risk assessment tools• For rapid assessment

• For alternatives assessment

• Without these will have collection of data

REACH will require development of clear guidance on how to assess chemicals, substitutes, and trade-offs

REACH will require tools to understand risk reduction activities/progress towards goals

To be more effective, REACH needs to include more data on process level use and exposure

Page 24: Impacts of the European Commission’s REACH Proposal on Risk Assessment Joel A. Tickner, ScD and Ken Geiser, PhD Lowell Center for Sustainable Production

Final thoughts…Final thoughts…

If REACH internalizes holistic consideration of chemical lifecycle risks and alternatives then it has achieved some measure of success

Too little attention has been paid to substitution and analysis of alternatives

Equally applicable with what to do about HPV/VCCEP in the US

An opportunity to guide manufacturers towards safer chemicals and syntheses.

If REACH internalizes holistic consideration of chemical lifecycle risks and alternatives then it has achieved some measure of success

Too little attention has been paid to substitution and analysis of alternatives

Equally applicable with what to do about HPV/VCCEP in the US

An opportunity to guide manufacturers towards safer chemicals and syntheses.

Page 25: Impacts of the European Commission’s REACH Proposal on Risk Assessment Joel A. Tickner, ScD and Ken Geiser, PhD Lowell Center for Sustainable Production

Lowell Center for Sustainable Production Chemicals Policy Initiative Website

www.chemicalspolicy.org