The European Chemical Agency (ECHA) has recently added ten more substances of very high concern (SVHCs) to its Candidate List for Authorisation, bringing the total number of substances on the list to 191.
Now that these new substances have been added to the Candidate List, businesses have legal obligations should they choose to continue using them either on their own, in mixtures or in articles. If you supply articles containing a concentration above 0.1%, you now have communication obligations to customers and consumers further down the supply chain. You also have six months from the substance’s inclusion on the Candidate List (27/06) to notify the ECHA.
Below is a brief profile on each of these ten new substances to help you identify them and their associated risks, as well as to avoid the use of them in your products and processes.
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These substances, following their addition to the Candidate List, will now also be considered for addition to the Authorisation List. If they are added to the Authorisation List, businesses will need to apply for special permission from the ECHA to continue to use the substance once its sunset date is surpassed.
In anticipation of this, companies should aim to be proactive and either eliminate these substances from their production processes or, if this is not possible, look to use a less dangerous substitute substance.
Elimination is the best way to mitigate the risks of a dangerous substance and is top of the COSHH hierarchy of control. It involves removing the need to use the substance by changing your processes and potentially any products you manufacture. If elimination is not possible, the next step on the hierarchy of control is to substitute the dangerous substance or process with one less dangerous, reducing the associated risks as much as possible. Either elimination or substitution can be achieved via a three-step process:
Identify - look for alternative process methods with the aim of removing the need to use the substance entirely. If this is not possible, identify the potential substitute substances available.
Compare - carry out a risk assessment for all the alternatives against the substance that you are looking to eliminate or substitute and compare the results. At this juncture, the relevant legislation should be checked to ensure that the alternatives are both legally compatible and to gauge the minimum health and safety standards you will be required to meet.
Decide - a decision should then be made on a best course of action. Factors to consider include; regulatory needs, technological possibilities, impacts on quality and efficiencies, costs and training for the new product.