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HCF 2019 Panel 1: Matti Vainio

Panel 1: How to choose the best possible risk management option to regulate substances of very high concern

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HCF 2019 Panel 1: Matti Vainio

  1. 1. Does REACH authorisation work? Helsinki Chemicals Forum Matti Vainio, Ph.D. (Econ) Head of Risk Management Unit European Chemicals Agency 23 May 2019
  2. 2. 2 Risks reduced • 1/3 of companies improved risk management measures • SVHC uses have become significantly safer System costs ~€25m/year (for 50 applications/yr) ~1/3 on applications, 1/3 on risk control and 1/3 on decision making Source: REACH Review of the Commission (2017) How effective is authorisation to improve the handling of SVHCs?
  3. 3. 3 How effective is it in triggering substitution?  Almost ½ of companies surveyed (n=63) had substituted  Signalling works: reaction to candidate listing of a substance “REACH Authorisation seems to be a major (but not the only) driver for substitution” (Impacts of REACH Authorisation, European Commission 2017)
  4. 4. 4 Two examples Murano Glass, IT From arsenic trioxide to cerium oxide and ground granulated blast furnace slag. European Project From Cr(VI) to “diamond-like-carbon” coating of cylinders for printing and packaging Italian government funded research leading to discovering of safer alternatives. Substitution took place. Arsenic concentrations in Murano air dropped by 98 % (from 200 ng/m3 in 2014 to 4 ng/m3 in 2016). Did not apply for authorisation. Developed prototype system and enabled technology owners to establish joint ventures and licensing deals for wider market uptake in 2019. Source: Horizon 2020 https://cordis.europa.eu/project/rcn/206525/factsheet/en
  5. 5. What have we achieved with authorisation that we could not have done with restrictions? • Reverse the question? • From MS point view: Quick action to reduce risks and to substitute • Information revealing on about uses and alternatives • Who pays and for what? • Implementation of 20 restrictions estimated to cost €290m/year • System cost of applications for authorisation (43 substances) about €25m/year • State aid compatibility • Finance (e.g. Horizon Europe) possible for authorisation
  6. 6. 6 Does REACH authorisation work? Good functioning of the internal market Risks properly controlled Substances progressively replaced by suitable alternatives  System cost relatively low – Improvements needed in applications, predictability and system efficiency – Unknown/hidden costs?  Risk reductions are often well demonstrated – Risks should be further reduced  Substitution is taking place ‒ More could be done Where we areObjective
  7. 7. 7 So why does authorisation have few friends? • Over (?) ambitious expectations on • what (upstream) applicants actually know about use and alternatives • what information (effortlessly) passed up and down supply chain • Legal text in not unambiguous • What are technically or economically feasible alternatives? • What are benefits for the applicants vs the society? • Some think it is “easy” not to authorise • Applications are made for a reason • Asymmetric information • “Similar” is not the same as “same” • Authorisation system is still very new in its operation • What is the right level of scrutiny?
  8. 8. Thank you! Subscribe to our news at echa.europa.eu/subscribe Follow us on Twitter @EU_ECHA Follow us on Facebook Facebook.com/EUECHA matti.vainio@echa.europa.eu

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