In an article published on March 4, 2019, non-governmental organization (NGO) ChemSec announced the release of its report “Lost at SEA*”, which critically reviews the use of socio-economic analysis (SEA) under the European REACH chemicals framework. Companies wishing to use certain hazardous chemicals in the EU, known as substances of very concern (SVHCs), are required by law to apply in advance for authorization to use them. An SEA is required as a part of this process. ChemSec writes that “the company needs to demonstrate that the societal benefits of continued use are greater than the risks, and according to the company applying for an authorization, this is of course always the case.” The report criticizes current implementation of SEAs under REACH arguing that “the socio-economic analysis only make[s] good on the latter half of its name – the economic part,” but that “soft values such as human health and protection of the environment do not fit into the equation and are mostly ignored.”

Cost-benefit analyses are used to compare costs of the regulation restricting an SVHC’s use to the benefits of restricting it, which needs to involve quantifying aspects such as human life and the environment. “Aside from this being ethically questionable, it is almost impossible to quantify such benefits,” ChemSec writes. “The applicants very seldom analyze the economic aspect in a wider sense than their own financial situation.” The report evaluates “the SEA that forms part of the REACH Authorization process and argues that the current practices in preparing SEAs and the way that [the European Chemicals Agency’s scientific committee’s] opinions are presented do not yield satisfying results.”

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ChemSec (March 4, 2019). “Socio-economic analysis within REACH isn’t “socio” at all.

ChemSec (March 4, 2019). “Lost at SEA*: The information policymakers actually need from applicants and SEAC opinions.

Andrew Turley (March 12, 2019). “NGO report: socio-economic analysis under REACH failing policymakers.Chemical Watch