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.