In the light of “fitness check”, streamlining of REACH Authorisation process and “better regulation” in general, there is an ongoing debate around the legislation for Occupational Safety & Health (OSH) and REACH. There have been calls to exclude substances from REACH Authorisation that are also covered by limit values under OSH to avoid overlap between these two sets of legislation. ChemSec is very concerned, since REACH in synergy with OSH provides important protection for workers.
Policy makers need to take a broad approach in their assessments of whether to regulate a chemical or not. Since the ultimate aim is to protect human health and environment, while stimulating economic growth at the same time, one must include the costs and benefits for all involved parties. Failing to do so will cause regulation to misfire and favour laggards instead of frontrunners, as well as create barriers to innovation and weakened protection for the environment.
To date a number of chemicals have been officially identified as EDCs under the existing European chemicals regulation REACH. This shows that EDCs can be identified on a case-by-case basis even in the absence of criteria. Using this approach, ChemSec has identified 32 EDC substances that can be regulated today under the existing legal framework.
Disfavouring companies that produce or use alternatives restricts EU innovation potential.
ChemSec urges the Commission not to lose the essence of REACH while simplifying and streamlining the authorisation process.
ChemSec’s comments on the Commission proposal “Streamlining and simplifications of the authorisation process for some specific cases” (Doc. CA/81/2014)