TALKING HEADS Perspectives TWO INDUSTRY
Andreas Dodos, Chairman of the European REACH Grease Thickener Consortium, Eldon’s
With special thanks to Graham Whale, Chair of the ERGTC TWG, for his contribution to this article Advantages of REACH
EU Regulation 1907/2006 known to all of us as REACH (Regulation for Registration, Evaluation, Authorisation and Restriction of Chemicals) entered into force on 1 June 2007 to replace the former EC legislative framework on chemicals. One of the disadvantages of the previous system was this legislation had become fragmented as this evolved over time. The distinction of chemicals as “old” and “new” was made depending on their introduction status in the European Community before or after the 18th September 1981 allowing for the listing of substances in the EINECS or ELINCS directory respectively. Under the previous regulations it was the responsibility of the authorities to evaluate the risks and hazards posed by the use of a specific chemical to human health and the environment. Unfortunately, this process proved very inefficient with only a limited number of chemicals being properly evaluated over 20 years with only 141 high volume chemicals being prioritised since 1993.
REACH places the burden of proof on companies to comply with the regulation and demonstrate “safe” use of their products. With this change it is expected that between 60 and 100 thousand substances will have had registration dossiers submitted by manufacturers or importers by the end of May 2018 to enable the continued marketing of their products in the EU. The change of emphasis from authorities to industry is in line with the “polluter pays” principle which is endorsed in other regulations. In effect, under REACH he who puts a chemical on the Common Market has to demonstrate the safety or provide the measures to allow for safe use of this product and thus the cost associated with
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the above process is carried only by the users of a particular chemical. However, it could be argued that as the final stage of the supply chain, all chemicals are used directly or indirectly in consumer products, so ultimately everyone pays for the additional REACH cost through their everyday or extraordinary purchases. This is a societal cost which has yet to be calculated.
One of the arguments to support the introduction of REACH in the EU is that, by identifying potential dangers to human health and the environment, lives could be saved and significant cost savings made, particularly through healthcare. In one of the early EU REACH related publications it was argued that around 4,500 lives and approximately 50 billion euros would be saved in the 30 years after REACH implementation. This translates to a 0.1% reduction in the burden of disease in the EU which significantly outweighs the 2.3 billion euros anticipated burden on the European chemicals industry. However, these figures have yet to be substantiated.
There are other advantages that are in many cases industry specific. As explained below, this applies to the European lubricants industry, where during the process of complying with the REACH regulation, the industry has developed and hopefully will continue to do so in the future.
Due to the nature of lubrication, product development has always been performance driven rather than chemistry driven. In this industry we have the interaction of a performance fluid, which is the lubricating oil or grease, with a mechanical or
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