Identification of Substances of Very High Concern
A Roadmap for Industry
► Key steps
1. Mobilisation and first assessment
Prior to any discussion or rumour of the likely identification of an SVHC, which means the inclusion of a substance on the Candidate List for eventual uptake in the Authorisation List, or Annex XIV, each company is advised to:
- Identify if any substance meeting the criteria for consideration as SVHC is used in their installations, as a substance or in mixtures. This is not an easy task, as some substances will not readily be identified, being part of a mixture or an article. To complicate matters even more, some of the articles companies buy may have been manufactured using the substance that is no longer present in or on the article. Examples of this are machinery or aircraft parts that have been plated and on which a chromate or a nickel salt is no longer present. If all Labels and Safety data Sheets are checked, the checklist should also circulated to the process and maintenance engineers, among others. All substances identified as potentially at risk should be put on a Watch List.
- Importance / criticality of the use of the substances on the Watch List should be assessed, as well as the possibility to use an alternative that does not have a similar hazard profile. The regulatory history of the substances may be of interest as there are substances that are more likely candidates because of an existing public perception or a known interest from a Member State (lead is an example). This exercise allows companies to rank the importance of the Watch List substances for its operations and prioritize stakeholder involvement and data collection.
- Assess the role the company could play in the process of defence of the uses that are critical. Is the company manufacturing the substance, involved in formulations, using it in its processes? Or is it an end-user depending on articles whose production involves the use of the substance?
These are factors that will determine the type of engagement with the value chain and the type of contributions the company will make. You may, for example, discover that your company is very dependent on a subcontractor who may not have the resources to solidly defend its case and who may need some support…
Many actors within the company will have to be involved
- Management give the green light for the internal efforts and external actions
- REACH coordinators set up a plan for establishing an inventory of substances that may qualify as possible candidates for SVHC identification. Once the inventory or Watch List is established, it may be their responsibility to suggest a ranking of substances to defend for all or some of its uses or to suggest substitution planning
- Marketing provide data on markets and trends and to open doors down the value chain
- Technical and R&D specialists clarify the criticality of the substances by identifying uses and functions as well as possible alternatives
- EHS departments consider collecting or refining exposure data
- Supply management participate in the risk inventory and help establish contacts up the supply chain
Outside information sources such as consortia, industry associations etc. may usefully be involved.
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Nickel Institute. The Nickel Institute is not responsible for the accuracy
of information provided from outside sources.
Users are advised to seek their own professional advice.