Applications for authorisation are submitted in a way that severely complicates the work of the ECHA Committee experts that are to evaluate them. They frequently contain excessive non-essential information or are unspecific about the actual use of the chemical. In addition, the overall quality of some applications is low (missing calculations, data based on assumptions rather than real-life data, etc.) The authorisation procedure also fails to incorporate a broader analysis of all market actors affected by the committee decisions, instead only taking the applicants interests into account.
“This makes it really hard to evaluate if the applicants really should be granted authorisation to use hazardous chemicals or not. In fact, we know that in many cases there are chemical producers out there with safer, viable alternatives as well as competing businesses that have put a lot of resources into substitution, ending up with better, but sometimes more expensive products. Both these groups would need to cope with serious disadvantages on the market if authorisations were granted under current conditions”, says Sonja Haider, ChemSec Policy Advisor.
A pressing issue is the fact that upstream applicants do not specify the intended use of chemicals. For example, “functional chromate plating” is too broad a definition to determine what uses are being applied for and whether there are available alternatives.
“To remedy this, ChemSec has prepared a matrix that can be used to properly map the intended uses, and we hope ECHA would like to consider using it in their work”, says Sonja Haider.
ChemSec is participating in the ongoing SEAC (committee for socio economic analysis) meeting this week in Helsinki, Finland, which is where applications for authorisation to use hazardous chemicals are being evaluated. During the meeting ChemSec is raising three suggestions for changes to the process, in order to facilitate the work of SEAC and remedy the problem of low-quality applications.
- Include a wider perspective on costs and benefits in the analysis – not only those of the applicant.
- Require upstream applicants to specify the scope of the application – including detailed uses and functions of chemicals and whether there are available alternatives.
- Procedural changes – like page limits and quality indicators in applications and more.
ChemSec’s suggested changes can be read in full here: