The future of
Chemicals Regulation after the EU Referendum, Response of the United Kingdom Lubricants Association
The United Kingdom Lubricants Association, as the recognised voice of authority and trade association representing the UK lubricants sector, welcomes the opportunity to respond to the Environmental Audit Committee’s inquiry into chemical regulation after the EU referendum.
The importance of the UK lubricants sector to the economy The lubricants sector is a cornerstone of the UK economy. At an estimated 555,365 metric tonnes a year with a value of £1.265bn, the lubricants sector underpins all forms of industrial activity across all sectors within the economy, from automotive, manufacturing and marine sectors, to aviation, aerospace and metalworking. The future success of the lubricant sector is key to the future growth prospects of the wider economy. A thriving lubricants sector will support future economic growth and expansion. A diminished sector will restrict the ability of the UK economy to grow in an effective and sustainable manner, and hamper the creation of economic prosperity for all.
The lubricants sector reflects the overall level of economic activity. Consumption of lubricants correlates closely with the country’s Gross Domestic Product (GDP). When an economy is doing well, consumption of lubricants increases to reflect greater industrial activity and higher levels of transportation. When the economy turns down, industrial activity reduces and consumption of lubricants declines.
The role played by the UK lubricants industry on safeguarding the environment
and reducing the country’s carbon footprint cannot be underestimated. The emission savings made by moving from mineral-based oils to newer synthetic oils over the last ten years in automotive and gas engine oils has contributed towards a saving of 1.9 million tonnes of fuel consumed by transport in the UK in 2013, or 2.5 billion litres of fuel. This is the equivalent of 80,000 fewer fuel tankers on the road each year.
It is therefore in the interest of a sustainable economy to support a thriving and healthy lubricants sector.
The role of UKLA in the UK lubricants sector?
The UKLA is a trade association that supports sustainable sector development and thereby economic growth, by;
Ensuring greater regulatory compliance amongst member companies through cascading emerging regulation and improving member companies’ awareness of requirements through publications, seminars, forums and networking.
Developing corporate standards of performance in the sector by supporting the development of individual competence demonstrated through member communications (magazine, website), sharing best practice through industry events, forums and networking opportunities, and accrediting best practice through training courses and corporate membership programmes.
The UKLA therefore is core to supporting a thriving and healthy lubricants sector which supports economic growth in the UK and the EU.
ENQUIRY QUESTIONS A. TRANSPOSITION
What particular challenges will the UK Government face when it seeks to transpose REACH into UK law through the “Great Repeal Bill”? The principles of REACH are supported and accepted by the lubricants sector. It is imperative that we continue to safeguard and enhance the reputation of the sector by continuing to provide safe, effective products for our end users; and a safe working environment for our employees.
However the way REACH has been interpreted and implemented by ECHA, the European Chemicals Agency, is overly bureaucratic and overly burdensome especially for small businesses who face six figure costs to register their chemicals, substances and mixtures with the agency.
The challenge for UK Government will be to continue to maintain the principles of REACH with appropriate links made to other international chemicals regulation such as the Classification, Labelling and Packaging regulation (CLP) itself based on the United Nations Globally Harmonised System of Classification and Labelling of Chemicals regulation (GHS), and the SEVESO Directive.
At the same time Government needs to ensure that UK businesses are not disadvantaged by creating a new UK-only REACH scheme which has little transferability with the existing European Union scheme, while at the same time ensuring that small businesses are not overly penalised by the high costs of entry into such a UK-based scheme.
58
LUBE MAGAZINE NO.139 JUNE 2017
Page 1 |
Page 2 |
Page 3 |
Page 4 |
Page 5 |
Page 6 |
Page 7 |
Page 8 |
Page 9 |
Page 10 |
Page 11 |
Page 12 |
Page 13 |
Page 14 |
Page 15 |
Page 16 |
Page 17 |
Page 18 |
Page 19 |
Page 20 |
Page 21 |
Page 22 |
Page 23 |
Page 24 |
Page 25 |
Page 26 |
Page 27 |
Page 28 |
Page 29 |
Page 30 |
Page 31 |
Page 32 |
Page 33 |
Page 34 |
Page 35 |
Page 36 |
Page 37 |
Page 38 |
Page 39 |
Page 40 |
Page 41 |
Page 42 |
Page 43 |
Page 44 |
Page 45 |
Page 46 |
Page 47 |
Page 48 |
Page 49 |
Page 50 |
Page 51 |
Page 52 |
Page 53 |
Page 54 |
Page 55 |
Page 56 |
Page 57 |
Page 58 |
Page 59 |
Page 60 |
Page 61 |
Page 62 |
Page 63 |
Page 64 |
Page 65 |
Page 66 |
Page 67 |
Page 68 |
Page 69 |
Page 70 |
Page 71 |
Page 72