Examining the Relationship of Chemicals and the Circular Economy
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The overall theme throughout HCF 2016 was on economic development and sustainability with a particular emphasis on the opportunities and challenges the circular economy poses for chemicals regulation. A circular economy is an industrial economy that is producing no waste or pollution. It is a move away from the “take, make, dispose” manufacturing model, and replaces cradle-to-grave design with cradle-to-cradle, which is the driving philosophy behind the field of sustainability.
Thus while ECHA strives to regulate hazardous substances, it is also promoting the use of alternative non-hazardous options that eliminate the need to register at all, resulting in reduced hazardous chemical use, reduced waste and reduced risk: a win-win situation for everyone.
11th Stakeholder’s Day Preceded HCF Conference
Preceding the conference was the 11th Stakeholder’s Day, which attracted 300 attendees from more than 30 different countries, including those in the European Union as well as India, Russia, Japan, Turkey and the USA. The day was devoted to discussing how to achieve a successful REACH registration, how to ensure high dossier quality, and how registrations are used.
Geert Dancet, ECHA’s Executive Director, opened the venue, and announced ECHA’s recently published 5-year report that examines how chemical use has changed as a result of REACH. According to the report, 168 substances of very high concern (SVOC) have been identified, 31 of which require review and 20 of which are restricted. The report concludes that as a result of REACH there are more SVOC controls and that chemical use now delivers safer conditions for manufacturers and downstream users.
The next REACH deadline, May 31, 2018, by which all chemicals must be registered, was emphasized. This particular deadline is expected to swamp ECHA with up to 60,000 dossiers, about five times more than they received in 2013. Up to 25,000 substances are expected to be registered as compared to just 3,000 in 2013. This increase in volume is anticipated to come from small to medium sized entities (SMEs), including more registrants without co-registrants. Guidelines were published at the end of May 2016 to provide additional details about data sharing and low-risk, low-tonnage substances.
ECHA also introduced a new generation of IT tools for IUCLID, Chesar, and REACH IT designed to reduce the number of user manuals and drive ease of use, with a focus on streamlining the registration process. All three tools are better integrated and less confusing to navigate that previous iterations.
As REACH registration matures, ECHA is paying attention not just to substance identification but also use descriptions and hazard assessment conclusions.
Presentations Addressed REACH Regulation Compliance
All the presentations focused on enabling organizations to better address the REACH regulation. One presentation in particular stood out. Janet Greenwood, secretary for the UK’s Chemical Regulations Self Help Group, provided a case study concerning the greatest registration difficulties, including finding out who the lead registrant is for an existing registration and what to do if no lead registrant exists. She also examined the issue of registration costs. For instance, an SME with a turnover of £3.6M, net profit of £110K and 21 staff with 8 substances to register as the lead and only registrant will incur estimated costs of £60K per substance for a total of £400K. If the SME is a member registrant, the estimated costs drop to £33K per substance for a total of £264K. This is obviously an unsustainable number either way. The options are to register only what the SME can afford, but lowering the Letter of Access costs would reduce the impact of REACH significantly. Greenwood said “the costs of REACH have to be weighed against access to the market and thus doing business in the EU. To offset these costs there will need to be an increase in revenue in the EU under REACH.” Another option would be to increase the cost of the product, but this may not always be feasible. Greenwood’s presentation is available along with all other Stakeholder Day presentations at http://echa.europa.eu/news-and-events/events/event-details/-/journal_content/56_INSTANCE_DR2i/title/11th-stakeholders-day.
Triskelion’s Hans Marquet pointed out that knowing your substance involves more than knowing the melting point, viscosity, relative dew point, etc. In fact, while many substances perform well at their specified task, but there is often little data about hazard attributes. This lack of data is one of the greatest impediments to registration, and not just the responsibility of the manufacturer, but also required from the organization that uses the substance in their own products. Much of this data should be on the Safety Data Sheet (SDS) but is often not, resulting in the greatest source of REACH non-compliances.
These challenges contribute to the difficulties faced by ECHA in understanding hazardous chemical use in the EU, by substance manufacturers in understanding the substance, and by research organizations that use the substances in their development processes in understanding the impact of the substance on their chemicals-based end-products.
HCF 2016 Examined Chemicals Impact
During the two-day conference that followed Stakeholder’s Day, keynote speaker Achim Halpaap, Head of UNEP’s Chemicals and Waste branch, provided some telling statistics about chemicals management and the importance of the move toward a circular economy. He stated that the world economy and global market is expected to quadruple between 2010 and 2050. Halpaap emphasized that there are fundamental structural changes occurring in the chemical industry what with China becoming a dominant player and large multinationals becoming larger. He also pointed out that there is a double standard: chemicals that are classified as unsafe in one part of the world should not be “safe” in another, citing lead in paint as just one example. UNEP’s booklet “Global Chemicals Outlook II 2018” examines this subject in detail.
The European Commission’s Bjorn Hansen led the panel on the Circular Economy, drawing attention to chemicals substitution, reduction, non-toxic material cycles, risk management, recycling and cross-border circulation of raw materials. All of the panelists emphasized the challenges of changes to business models as a result of increased regulatory oversight. One panelist, Michael Warhurst, Executive Director of CHEM Trust, pointed out the issue of Bisphenol A (BPA) in thermal paper from cash register till receipts being recycled into pizza boxes and thus creating a inadvertent downstream issue of food contamination by an endocrine disrupting chemical. Hansen stated that “as the world increases from 1B to 2B consumers, there will be an increase in use of consumer goods. As knowledge develops, we find more and more hazards in those goods. Thus the transition that needs to happen needs to stimulate innovation while eliminating chemicals coming in to the waste stream.” There are opportunities for research organizations within these parameters, specifically the reduction in hazardous material waste can lead to significant cost savings for the organization. Hansen added that “REACH is the start of this process and has sensitized industry to think about safety and driven awareness by a broader community that everything is chemicals-based.”
Each of the subsequent panels addressed specific concerns associated with these challenges. From the fact that less than two percent of perfluorinated chemicals are registered under REACH to more efficient sharing of regulatory data globally to case studies on how to improve plant safety during research and production processes, HCF 2016 examined challenges and solutions to chemicals use and management from a number of perspectives.
Next year HCF returns to Helsinki’s Messukeskus Convention Centre from 8-9 June 2017. For details, visit http://www.helsinkicf.eu or http://echa.europa.eu/regulations/reach.