London - Meeting the requirements of the EU's REACH chemicals safety regulations has been a long, hard journey for European chemicals makers and their customers over the past 15 years. The vast scale of the effort, which continues to grow year-by-year, raises the question: for what return?
The payback is two-fold, believes Jo Lloyd who guided the Chemical Industries Association activities around REACH from 2000 until earlier this year, when she left the UK chemicals and pharma manufacturers body to join a private industry consultancy.
The chemicals industry, said Lloyd, benefits both from knowing that it is 'doing the right thing' in terms of ensuring that its products do not pose human health risks, and from the huge and growing database on the safety of chemical products that has been created.
When REACH came along around 15 years ago, the aims was to reverse the burden of proof: leaving it down to industry to prove the in-use safety of its products, all the way down the supply chain.
The scheme was introduced for high-volume chemicals in 2010, followed by medium-volume chemicals in 2013, with chemicals produced in volumes down to 1 tonne a year to be included from early 2018.
Since the arrival of REACH, said Lloyd, “a staggering number of assessments have been done. We are nearing now the 10,000 mark of [registrations] going through and we are going to get an awful lot more coming through between now and 2018.”
“We now have a global database, which is accessible to everybody around the world,” she added. “It is publicly available information you can search any of those chemicals and it pulls out data on its physical hazards, environmental hazards and human health hazards.
“You also know that the rigour of the ECHA (European Chemical Agency) agency [behind] at that data.”
What it costs
Lloyd said that, when asked, many companies just don’t know what they have actually spent or are spending on REACH
“There is no cost base there any more, it is just that REACH happens,” said Lloyd, adding that “I don't think we'll ever really know the full cost of REACH.”
In 2010, when all the high-volume chemicals went through, registration costs were estimated at anywhere from €20,000 all the way up to €500,000 per company.
And while the cost is likely to be a lot less for the registration of small-volume chemicals in 2018, Lloyd said that CIA members are saying they have many, many more registrations than in 2010 and 2013 so the costs “will still get into some very big numbers.”
Meanwhile, smaller companies with no experience of REACH from 2010 or 2013, are now going to have to plan their registration projects with unknown costs, warned Lloyd who said that some SMEs are struggling with that and “don't really know what to do.”
Lloyd went on to note that all the impact assessments originally carried out for REACH were “way, way out" in terms of cost assessment
"Costs were only done from the point of view of chemicals and chemicals manufacturers, but now we realise there are whole new layers affected right throughout the supply chain,” she said.
For example, Lloyd noted that the first company to do a follow-up REACH assessment was not actually a chemical producer: it was Rolls-Royce.
“So it has really now touched companies that we never really envisaged in those initial impact assessments," she commented. "It was modelled on a very, very, short supply chain. There were quite a lot of assumptions also made about what data was available and what new data would be needed.”
Summing up, Lloyd said: “We have to come back to what REACH is all about: assessing chemicals, finding out which ones are unsafe and then actually doing something about it.
"Without a doubt there will be some hard decisions and around communicating that. That is the part that we really have not got right yet. We have now a brilliant mass of data we just have not communicated it very well down the supply chain,”
Meanwhile, she said, many companies are continuing to use substances of very high concern because they have always used them for particular applications.
“Now that we have the data, maybe, we can show that that is not the best way to use them, concluded Lloyd. “Maybe they are putting lives at risk, maybe they are putting the environment at risk.
“That is a message the CIA and other members now are certainly understanding and giving to their customers, even though it is not necessarily a message they want to hear”.