Structure of Risk Management

24 For instance, a risk management decision may be based on hazardous properties regardless of exposure levels [162]. 

One reason for the linear substance-by-substance approach is that current EU risk assessment requirements depend on the amount of a substance produced or imported. As the tonnage level increases, so does the number of toxicological tests. The rationale, advantages and disadvantages26 for tonnage triggers can be summarised as follows [164]  

25 EU chemical risk assessment and management decision-making processes appear to be separated into five or more Techmcal Committees and Working Groups attended by different regulators and overseen by at least three Directorate-Generals of the European Commission. 

26 A more detailed criticism of the use of tonnage triggers is provided by the Royal Commission on Environmental Pollution (RCEP) in its publication Chemicals in Products [166]. 

27 To illustrate this fact, one simply needs to ask, to what extent is the consequence of a child developing cancer more severe than that for an elderly person or how probable is exposure to a chemical product for a consumer who cannot read instructions Answering such questions involves considering many socio-economic variables the interpretation of data may vary significantly between individuals or societal groups. 

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