Note: This is the third letter in an on-going discussion between ChemSec’s Executive Director Anne-Sofie Andersson and her counterpart at Echa, Björn Hansen. You can read the first letter from Ms Andersson here and Mr Hansen’s response here.

The picture shows another pair of famous pen pals who also skipped social media and wrote each other the old-fashioned way, Simone de Beauvoir and Jean-Paul Sartre.

Dear Mr Hansen,

Thank you for your thorough answer to our concerns and to the specific questions we put forward. I am glad to hear that you enjoy your new position and I appreciate your dedication to make ECHA work more effective.

As an agency, I understand that you need to follow agreed procedures, such as the SVHC roadmap, and looking at this specifically I understand your view that the roadmap is doing well.

Coming from the outside, and therefore possibly with a zoomed-out perspective, I stand firm in my opinion that the pace of populating the Candidate List has been far too slow. I cannot see that this will improve within the current roadmap.

I am glad to read from your answers that we agree on the following:

• Non-registered substances can also be relevant for the Candidate List
• CMRs are not necessarily adequately controlled through requirements following on classification
• It can be advantageous to have restricted substances also on the Candidate List

Let me also clarify that the statement from your predecessor Mr Dancet on industry pressure comes from an interview in Euractive, October 2017. This was his answer to the specific question on whether any ”risky” substances had been taken off the market because of REACH. I think this is was actually a very relevant question; how are we doing on using REACH for taking hazardous substances off the market?

In line with this I must unfortunately say that I do not feel reassured by your answers on question number four and five, relating to how you will ensure that substances do not get stuck in expert groups, but that SVHCs gets listed at a higher pace; and on how to assure that certain industry strategies to slow down the system will not be successful.

You say that data generation takes time, which is very true. However, we would like to see ECHA´s committees and expert groups to more often act on the available data without routinely asking for more information. Asking for more data is very effectively slowing down substance evaluation and identification of new SVHCs, not only because data generation takes time, but because requirements for new data are routinely overruled.

It is difficult to set protocols on how to avoid this paralysis by analysis. There is rather a need to change the organisational culture, and I hope you will use your influence to improve the situation. For example, a better use of the precautionary principle will help to speed up the identification of SVHCs.

Thank you for taking the time to have this very important discussion with us. We look forward to follow the development and to stay in close discussions with you.

Kind regards,

Anne-Sofie Andersson
Executive Director, ChemSec