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The Commission's to-do list following the REACH review lacks actual things to do


The Commission’s to-do list following the REACH review lacks actual things to do

Published on 14 Jun 2018

At some point we’ve all been “the new guy” at work and this isn’t always a blast. You don’t know how the coffee machine works, the office lingo sounds really unfamiliar and you constantly have to ask how to do things. You are basically the office geek – and everybody knows it.

One interesting thing though with being the new kid on the block is when you take over responsibilities from someone else that already quit. As you rummage through the computer server, looking at your predecessor’s old work, you get a glimpse into the mind of that person.

One previous work situation of mine especially comes to mind. In this case my predecessor had left behind these very impressive-looking planning documents. There were Excel sheets upon Excel sheets with colour-coded columns, and if you entered information in the columns it went through several formulas set up in the background which gave you an answer in the bottom left corner.

There were also flowcharts that reminded me of some beautiful Indian mandalas more than anything else.

Mind-blowing stuff. Expertly done.

So I was surprised to learn that the management wasn’t happy with the results that this person produced. But after a while it dawned on me; this person was an expert planner – a roadmap rockstar and flowchart wizard – but she didn’t actually do anything.

As my experience has grown I have realized that in the “office world” you can actually make a career out of behaviour like that. But try that stuff in a hairdressing salon – spending time lining up the scissors and combs instead of cutting people’s hair, for example – and you’d be out of a job within a week.

This little backstory is the first that came to mind as I was reading through the Commission’s 16 action points following the REACH review – they’re simply loaded with plans to make even more plans.

Or, in hairdresser words: It’s a lot of talk about how to cut people’s hair instead of actually cutting it. All the work that culminated in the REACH review has been nothing more than a massive mapping exercise, costing millions in consultant fees – and the Commission’s conclusion is that more mapping is needed?

One of the great things with the review is that everyone now seems to agree that REACH has a real implementation problem. It’s moving too slowly. But when the European Chemicals Agency (ECHA) explicitly states that this is largely due to industry not providing enough chemical data – and in addition only about 25 percent of companies conduct a regular routine review of their REACH data – the Commission’s solution is yet another investigation as to why this is the case.

There is no need to evaluate this non-compliance. Everybody already knows this is because there are no incentives for compliance. The success of REACH hinges on industry information and the lack of it creates a severe bottleneck in the system.

Another dissapointing thing concerning the action points is the measurability. Deadlines are missing and vague wording is used, such as improving, increasing, gathering evidence, clarifying and continuing efforts, etc. This is very soft language for very important actions. The most frustrating thing is that even slight changes – real deadlines and concrete wording – would completely change the implications of the review.

There are even rumours in Brussels that Mr. Juncker himself played a big part in putting together the action points, changing wordings and striking things out. Who knows if it’s true or not – nevertheless, it’s obvious that the Commission is reluctant to put its foot down against industry laggards.

Like so many times in the past, the missing voice here is that of EU citizens. If we take a step outside the policy bubble, we know that around two-thirds of EU citizens are concerned about being exposed to hazardous chemicals in their daily life. And there is a strong scientific consensus that those concerns are not unfounded.

With that in mind I’d like to build on my old predecessor’s planning skills and present you with a roadmap of my own – complete with deadlines and measurable actions.

Ready? Here it is:

“Fix it”.

You may colour-code it yourself if you wish.