ETUC Conference on REACH - 11-12 March 2005

Improving REACH ETUC proposals for REGISTRATION

Werner SCHNEIDER DGB, Germany

ETUC Conference on REACH - 11-12 March 2005

general obligation for manufacturers and importers

to obtain information on their substances and

to use this knowledge to manage them safely

applies to 30 000 substances manufactured or imported into the EU in quantities > 1 tonne per year

Failure to register means that the substance cannot be manufactured or imported

Registration

ETUC Conference on REACH - 11-12 March 2005

Registration Deadlines

Yr 0 Yr 0 +3 Yr 0 + 6 Yr 0 + 11

(2017+)

>1000 t + CMR>1000 t + CMR

100 - 1000 t 10 - 100t

1 - 10 t

ETUC Conference on REACH - 11-12 March 2005

Registration requires manufacturers and importers to submit:

Technical Dossier: starting at 1 tonnes per year identity physiochemical properties toxicological data ecotoxicological data

Chemical Safety Reports: starting at 10 tonnes per year hazard classification (human health and environment) PBT and vPvB assessment if dangerous or a PBT or vPvB :

exposure assessment incl. exposure scenarios risk characterisation

The larger the volume, the greater the amount of data

to be supplied

ETUC Conference on REACH - 11-12 March 2005

Loopholes in the REACH proposal

Registration Dossier

Quantities (t / y) Nb of Substances

Technical Dossier CSR

1 -10 20,000 YES NO

10 - 100 4,600 YES YES

100 -1000 2,800 YES YES

> 1000 2,600 YES YES

No Chemical Safety Report for 20,000 out of 30,000 substances to be registered

Lack of basic information in the 1-10 t range

ETUC Conference on REACH - 11-12 March 2005

ETUC proposals

CSR for all registered substances

To ensure possible risks are controlled for 30 000 substances.

To achieve a better balance between costs and benefits.

To increase the synergy between REACH and OSH legislation.

ETUC Conference on REACH - 11-12 March 2005

ETUC proposals

Acute toxicity and biodegradability tests for substances in the 1-10 t range To ensure proper classification for 20 000 low

volume substances.

To enable very basic level for protecting workers, consumers and the environment.

ETUC Conference on REACH - 11-12 March 2005

OSOR : One Substance, One Registration

ETUC welcomes this proposal aimed at reducing the implementation costs to EU industry and the authorities.

ETUC’s precondition for supporting OSOR is that producers (manufacturers/importers) and downstream users remain fully responsible and legally liable.