REACH - A Critical Analysis

By focussing on filling the gaps in hazard data for chemicals on the EU market, the European Commission White Paper for a future EU Chemicals Strategy completely overlooked four fundamental questions, developed in Box 5.2. 

Which regulatory structures facilitate management and promotion of chemical safety in businesses  

How should EU decision-making be structured to facilitate Member State authorities reaching agreement on regulatory processes or outcomes  

More often than not, stakeholders disagree with each other on scientific risk assessments. While a company may conclude that a chemical does not present an unacceptable risk to human health or the environment, a regulator may identify the need to reduce a risk [473], Consumer or environmental non-governmental organizations (NGO) may push for regulatory action beyond that which regulators deem adequate to reduce a risk. 

In terms of the practicality of implementing REACH, no chemical safety report (CSR) appears to exist at the time of regulatory enactment of REACH. The concept of a CSR has therefore never been tested. The extent to which a substance-specific CSR can cover more than one specific use or be incorporated into safety data sheets (SDS) for preparations (i.e., chemical mixtures) needs development. 

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