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Published in Politiken

By Susanne Bruun Jakobsen & Christian Ege, the Danish Ecological Council

The European Chemical Agency, ECHA has now published its first drafted list of Substances of Very High Concern (SVHC) or chemicals that have to be authorised according to the rules of the new European chemical legislation, REACH, as this came into force a little more than a year ago.

The released list consists of 16 chemical substances only. A most disappointing result.

The authorisation procedure has been launched as one of the highlights of REACH. The idea is that companies who wish to produce or import substances of very high concern – i.e. compounds which are not banned, but considered to be very hazardous for the environment and/or man - will have to register their intention and to apply for an authorisation for any specified use(s) and for the placing of the chemical on the market.

Furthermore, companies are required in such cases to give information on substitution possibilities, e.g. by application of less hazardous substances.

From the now released list it can be seen which countries have submitted their proposals for the named chemicals. From Denmark no such proposals have been submitted in spite of the fact that the Danish Environment Protection Agency over several years has developed and maintained its own “List of Unwanted substances” containing a long series of chemicals which will in most cases meet the requirements for the abovementioned EU-list.

The question is: Why are Member States so reluctant in their proposing candidates for the list? It seems likely that the cause has to be found in the requirement for documentation that man and/or environment is actually exposed to these chemicals. But – Helas! - this is exactly what has to be studied and documented by the companies who want to produce and import the chemicals.

It is part of the REACH regulation that substances which are considered carcinogenic, mutagenic or toxic to reproduction, or which may be very persistent and very bio-accumulative in biological systems, shall be subject to special authorisation. This is expectedly also the case for so-called endocrine disrupting chemicals or others of ‘equivalent concern’. Scientifically, it is to-day an unchallenged fact that hundreds of all such chemicals can be readily and directly identified. But, incomprehensibly, only 16 names have been placed on the list, notwithstanding that this is not intended to be a list for banning, but rather an identification of chemicals as objects for special use permissions.

As an example it may be mentioned that the so-called brominated flame retardant, deca-BDE, is not included. This chemical has recently been banned for use in electronics due to its hormone-disrupting properties, but it may well be used in other types of products or materials, and indisputably it seems necessary to signal to industries, that any such case has to be subjected to an authorisation procedure. On the positive side, however, it is noted that the list contains the name of another brominated flame-retardant, HBCDD, which has so far not been banned. The same apply to the three so-called phthalate-plasticizers, DEHP, BBP and DBP. They have so far only been restricted in products which are targeted for use for infants or smaller children.

The list as it presently stands can only be seen as a bad start of the REACH-reform, reminding us on a time before the reform, when scientists and authorities were bound to submit ‘telephone directories’ of detailed information – not only on the hazardous properties of individual chemicals, but also on the detailed ways and means by which man and environment could be exposed. Therefore only very substances were assessed.

That situation was actually the background for developing REACH – a chemical reform for Europe in order to develop a chemically safer life for man and environment.