For the companies it affects, Authorisation is likely to be the biggest REACH challenge. But there’s no reason why it has to be – provided you stick to a few simple rules.
Applications for Authorisation are on the rise. Eight were submitted last year and ECHA expects 20 more during 2014. With 151 substances on the candidate list, and new substances appearing all the time, this is really just the start.
So it is no surprise that many companies are already investigating this relatively unknown part of the regulation. It is an intimidating prospect. An Application for Authorisation is both complex and costly, and most companies do not have the relevant expertise to call on. What is more, a failed Application will result in the inability to continue using the substance. So if your products are dependent on this use, you could suffer a significant blow to your business.
“The Authorisation process was always designed to be challenging,” says Meg Postle, Director at RPA, a UK chemical hazard consultancy. “The idea is to push companies towards substitution. They have to submit in-depth studies of the alternatives that should, to a large extent, pre-empt third party objections. For many companies, it will be much bigger than anything they’ve previously had to do for REACH”.
RPA is working on a wide range of Applications, including six of the
eight Applications relating to phthalates DEHP and DBP. In February, the company took part in the Trialogue meetings for these phthalates, which included discussion of the more than 120 comments received during the public consultation period and additional questions from the RAC and SEAC Committees.
But there are encouraging signs. ECHA has said that companies can improve their chances of success by ensuring their Applications are of a high standard. As an Application can take several years to put together, early preparation is essential. It is also important to get to know your supply chain. If it is not possible to ‘adequately control’ the risks associated with your substance, perhaps because there is no safe threshold exposure, you will need to accurately determine the impacts of a non-use scenario. Such an analysis is difficult, if not impossible, without the cooperation of downstream users.
