Tonnage thresholds

The Registration, Evaluation, Authorisation and Restriction of Chemical substances (REACH) regulations came into force on June 1, 2007. At that time, it was estimated that there were approximately 100,000 existing chemicals, of which approximately 30,000 were marketed in volumes at or above 1 tonne per year. For these 30,000 substances, a registration dossier must be submitted. The registration requirements depend on the tonnage thresholds, as follows ... 

Substances produced in quantities of less than 10 tonnes per year include most of the chemicals used as textile dyestuffs and auxiliaries (CEC, 2003b). This illustrates the inadequacy of using tonnage thresholds as a measure of human exposure. Chemicals used to dye or treat cloth are present in our clothes and may leach from clothes through our skin into our bodies. We may also inhale the chemicals, after the skin has flaked off and become part of household dust (ENDS, 1994). Clothes are probably one of the major routes of human exposure to synthetic chemicals and the long-term effects of those chemicals should surely be investigated. 

Fatal accident rate Lost-time injury rate Capital cost of accidents Number of plant/community evacuations Cost of business interruption Cost of workers compensation claims Number of hazardous material spills (in excess of a threshold) Tonnage of hazardous material spilled Tonnage of air, water, liquid and solid effluent Tonnage of polluting materials released into the environment Employee exposure monitoring Number of work related sickness claims Number of regulatory citations and fines Ecological impact of operations (loss or restoration of biodiversity, species, habitats)... 

Maintenance and enhancement of competitiveness of the EU chemical industry. The cost of chemical testing will be high. A base set of data will cost around 85 000 Euros whilst a full data set for high-tonnage or hazardous materials may cost over 325 000 Euros. Within this constraint, EU policy will also seek to encourage substitution of hazardous chemicals by less hazardous ones. The raising of the current threshold for base set testing will also allow more materials to be evaluated under controlled conditions. 

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