The list of Substances of Very High Concern (SVHC) currently counts 161 substances of which 31 now require authorisation before use (the authorisation list). The list is intended to grow and currently another 22 substances are prioritised for uptake. This may become highly critical to a number of industries.
“Some products such as medicinal products are exempted from this regulation as pharmaceutical legislation applies to this area. However, drug manufacturing processes using chemical substances that are on the authorisation list must comply with these requirements,” Jens Tørsløv says.
Jens Tørsløv is Ph.D and Head of Projects at DHI, Environment and Toxicology, where they have specialized in chemical management and act as consultants. He stresses the sense of urgency in this matter.
“Many manufacturers may not be fully aware of the impact the authorisation requirements under REACH may have, or they may have the misconception that REACH is inapplicable to their production,” he says.
“REACH is putting pressure on the industry to identify new methods and replace problematic substances with other substances. Acknowledging that this is not done easily or rapidly, the users must apply for permission to use substances on the authorisation list to continue the use,” Jens Tørsløv explains.
Have DHI provide a SVHC strategy
A lot of industries may use SVHC or substances-soon-to-become SVHC during manufacturing. This calls for action! The companies need to identify SVHC in use and develop a strategy on how to act. Intermediates are exempted but for other substances on the authorisation list applying for permission is an option.
The experts at DHI know how to trouble shoot in this matter, firstly by knowing what to look for and secondly by knowing what to do with their knowledge.
It should be explored if authorities can be convinced not to place a critical substance on the authorisation list, by documenting the impact it has on business and by exploring other ways of regulation. In situations where no alternatives are available and the only use is in well controlled industrial settings, it may be worthwhile to try to argue to keep the substance off the list.
REACH does make it possible to influence the decision process. The REACH authorisation procedure is expected to be simplified as the European Commissionhas recently announced that they wish to simplify the process for authorisation, for instance of low volume substances and SVHCs for repair of certain long life articles. DHI is following the development closely in order to support each industry client with the best strategy.
Facts about DHI
Provides consultancy services within water, environment and health to
- public and governmental authorities
- industry sectors such as chemicals industries, ports, water utilities, energy, infrastructure and transportation
- consulting engineers and contractors
- Operates globally and has offices in more than 30 countries
For more information
www.tox.dhigroup.com/
