Why not control the risks instead of insisting on substitution

It is not possible to achieve adequate control of the risks of persistent, bioaccumulative chemicals. The fact that traditional risk assessment cannot reasonably be applied to such chemicals, and that a revised PBT (persistent, bioaccumulative, toxic) assessment is necessary, is explicitly recognised in the EU s Technical Guidance Document for risk assessment. Their intrinsic properties mean that there is a high risk of exposure at sometime during the lifecycle of the chemical or the article that contains it. Even small releases, if they are continuous, can result in significant exposures. This is why we see significant and, in some cases, escalating levels of brominated flame retardants, nonylphenols and other persistent chemicals in breast milk, umbilical cord blood and human tissue. 

Substitution, rather than risk management is therefore essential. Chemicals identified as of very high concern, e.g. carcinogens, reproductive toxins, those that persist and bioaccumulate in the environment and affect the hormone system, should be targeted for substitution based on their intrinsic hazards. 

By defining criteria for substances of very high concern, 

REACFI has already clarified which properties of substances make them a priority for phase-out. Any chemical that, by its nature, would require an authorisation to permit continued use should Immediately be targeted for substitution. This is 

The Swedish government has also reiterated the need to substitute substances of very high concern. These substances are estimated to be relatively few and would not overload the authorisation system. Sweden states that authorisation of such chemicals may be granted only if industry can demonstrate that no feasible alternatives are available the socio-economic arguments clearly outweigh the potential risks and emissions are foreseen to be negligible during manufacture, use and disposal.  

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