Identification of Substances of Very High Concern
A Roadmap for Industry
► Key steps
3. Action and Creativity
Preferably prior to any discussion by regulators at national or EU level, the value chain and the trade association or REACH consortia should prepare their case, starting with updating the Registration dossier and collecting data that may be useful when considering the relevance of substances for SVHC identification. It is a useful exercise to prepare a Risk Management Options analysis, to explore the main arguments a regulator may consider and to be creative when facing the prospect of having to suggest measures to reduce risks.
This may require a significant budget and it may be that a decision on this is not taken until a warning sign has come from a regulator. The preparatory work should however be performed as early as possible and priority may be given to some key data on actual risks, tonnages and economic relevance that can serve as input to the authors of the RMOA and in the Public Consultation.
As trade association or consortia, Do consider performing your own RMOA and accept the risk that you may have to consider suggesting an EQS, an OEL or other risk mitigating measure.
Examples of supply chain cooperation
As Authorisation implies an unprecedented involvement of the entire supply chain, which is a challenge to organise, it is good to start setting up a forum where different members of the supply chain can start discussions. The nickel value chains in France and Germany have initiated such cooperation. The French Nickel stakeholders group has proven very useful in collecting relevant data and providing input to the French authorities. The Risk Management Option analysis performed by the French scientific authority (ANSES) has been enriched by significant input from different Nickel stakeholders group members.
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