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REACH Authorisation
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Identification of Substances of Very High Concern

The Process

► What are the characteristics of relevant SVHCs? Preparing the Annex XV report and Public Consultation

1. In Practice

Risk Management Options Analysis
Identification of the Risk Management Options

Example of an assessment matrix of possible RMOs against the criteria of effectiveness, practicality and monitorability.

Example of an assessment matrix of possible RMOs against the criteria of effectiveness, practicality and monitorability

Industry may consider making suggestions in the "RMO 1" box related to the provisions that exist in current chemicals management legislation. The present regulatory provisions may, for example, be used to better avail and Industry may propose:

  • Effective, practicable and monitorable risk management measures and demonstrate adequate control of all identified uses
  • Substance evaluation
  • Setting a Community Occupational Exposure Limit (OEL)
  • Setting an Environmental Quality Standard through the Water Framework Directive
  • Updating BREF documents with a sector-specific emission limit value (Industrial Emissions Directive)

The more there is a perception bias against a sector or a use, the more challenging it will be for the industry to convince regulators that the proposed risk management measure will achieve its goals. Some risk management measures may also appear as difficult to monitor or as not realistic given the history of industrial practice in the sector.

Do not suggest a Risk Management Option that would only consist of implementing existing obligations or not be realistically enforceable in practice.

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