In an article published on August 7, 2018, by the non-governmental organization (NGO) International Chemical Management (ChemSec), Anna Lennquist, senior toxicologist at ChemSec, argued that the European Regulation on the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) is “working too slowly.”

In particular, she addressed the process of identifying substances of very high concern (SVHCs) and their placing on the Candidate List. The Candidate List currently has 181 entries whereas the SIN List contains 913 substances. The SIN List is managed by ChemSec and uses the SVHC criteria as defined under REACH. “An NGO manages the SIN List, which has made the process more systematic and less politicized than for the Candidate List,” Lennquist claimed.

She further stressed that “all substances that fulfill SVHC criteria belong on the Candidate List,” regardless of whether they are addressed by other regulatory actions. The Candidate List provides “predictability and allows time for phase-out,” is “a strong guide to substitution,” and there is “an automatic information requirement,” Lennquist outlined. Further, the Candidate List is “an important part of waste handling and the circular economy through amendments to the waste Directive,” she explained.

According to an analysis by ChemSec, “manufacturing of doubt, coupled with a lack of courage to act when it exists, is a very effective way to stall the [REACH] process.” However, the precautionary principle is embedded in REACH which “gives a mandate to act regardless of uncertainties,” Lennquist pointed out. The European Chemicals Agency’s (ECHA) second REACH review (FPF reported) found that the precautionary principle has thus far been overlooked. “The agency has the mandate to use the precautionary principle, no matter who opposes it,” Lennquist noted. “Industry will survive because of its ability to innovate and provide us with cleaner and safer solutions,” she added and concluded that “[t]he precautionary principle is key to getting REACH on track.”

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Anna Lennquist (August 7, 2018). “The usual suspects: Time to move beyond the most obvious SVHCs.ChemSec