There are four key takeaways from today’s REACH news that 20 new chemicals have been added to the Candidate List for a total of 73:
- Companies need to notify ECHA of uses around 20 new chemicals, deadline: June 2012
- Endocrine disruptor chemicals are making the List, thus are now targets for restriction (so look out BPA and the like)
- Chemicals can be put directly on the REACH Candidate List without a comment period (so be ready!)
- Companies need to be ready for the likelihood of SIN listers being restricted soon and without much warning.
Endocrine disruption. Today, officially, 4-tert-octylphenol was added to the REACH Substances of Very High Concern (SVHC) Candidate List. 4-tert-octylphenol was added to the Candidate List along with 19 other chemicals (listed below) for a total of 20 new substances of very high concern, octylphenol has a unique significance because it is the first Endocrine Disrupting Chemical (EDC) to be added to the REACH SVHC list.
The inclusion of 4-tert-octylphenol on the Candidate List opens the doors for the increased regulation of other EDCs. A number of other chemicals can be classified as EDCs including:
- Dioxin and dioxin-like compounds
- Polychlorinated biphenyls (PCBs)
- DDT and other pesticides
- Bisphenol A and other plasticizers
The endocrine system includes glands and hormones which regulate vital functions including growth, sexual development and behavior, metabolism, and reproduction. According to some, such as the National Institute on Environmental Health Sciences, EDCs are chemicals that may interfere with the body’s endocrine system and produce adverse effects — developmental, reproductive, neurological, and immune system — in both humans and wildlife. (View a comprehensive list of chemicals linked to endocrine disruption here.)
Companies can help ensure they’re prepared for any changes to the SVHC list by collecting supplier data on chemical ingredients as part of their quality assurance systems.
SVHC List REACHes 73. With 73 chemicals now listed, companies may have new legal obligations resulting from the inclusion of substances in the Candidate List. The obligations may apply to the listed substances on their own, in mixtures or in articles. For starters:
Producers and importers of articles have six months from today to notify ECHA by 19 June 2012 if both of the following conditions apply:
- the substance is present in those articles in quantities totaling over one tonne per producer or importer per year and
- the substance is present in those articles above a concentration of 0.1 % weight by weight
There are exemptions from the notification obligation if the substance is already registered for the use or when exposure can be excluded.
Among the recent 20 additions, 12 substances have been included in the Candidate List following the unanimous agreement of the Member State Committee, while the other eight did not receive comments challenging the identification as SVHC during public consultation, but were added to the list directly.
The 20 new chemicals on the REACH Candidate List are:
- Zirconia Aluminosilicate Refractory Ceramic Fibres
- Calcium arsenate
- Bis(2-methoxyethyl) ether
- Aluminosilicate Refractory Ceramic Fibres
- Potassium hydroxyoctaoxodizincatedichromate
- Lead dipicrate
- N,N-dimethylacetamide
- Arsenic acid
- 2-Methoxyaniline; o-Anisidine
- Trilead diarsenate
- 1,2-dichloroethane
- Pentazinc chromate octahydroxide
- 4-(1,1,3,3-tetramethylbutyl)phenol
- Formaldehyde, oligomeric reaction products with aniline
- Bis(2-methoxyethyl) phthalate
- Lead diazide, Lead azide
- Lead styphnate
- 2,2′-dichloro-4,4′-methylenedianiline
- Phenolphthalein
- Dichromium tris(chromate)
Companies can refer to the ECHA website for potential legal obligations resulting from the inclusion of substances in the Candidate List. If handling REACH is becoming too onerous, consider a REACH software solution or contact one of the many consultants on the subject. Consider joining an online forum of experts such as this LinkedIn Group — and communicating with colleagues about best practices in solving REACH. A little planning and foresight goes a long way, especially as REACH gets bigger and bigger. A pandemic, as someone we all know called it.
This article was co-authored by Pat King, who holds a bachelor’s in environmental science from Saint Laurence University.