The REACH pandemic.

Author:Buetow, Mike
Position:CAVEAT LECTOR
 
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THE world over, countries are adopting the core elements of REACH, Europe's three-year-old regulation on chemical use.

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As the EC's Environment Commission states, REACH aims to improve the protection of human health and the environment through the better and earlier identification of the intrinsic properties of chemical substances http://ec.europa.eu/environment/chemicals/reach/reach_intro.htm). But what it says next is equally important: "At the same time, innovative capability and competitiveness of the EU chemicals industry should be enhanced" [italics mine].

Indeed, what REACH and its relatives around the world will necessarily create is such a bewildering maze of paperwork and fine print that they will act as de facto trade barriers. As Greg Dripps, Dow Electronic Materials' global manager, Product Safety & Stewardship, noted recently, "Entry to markets will be slower."

Speaking at the IPC Symposium on Electronics and the Environment in mid July, Dripps pegged the shifting worldview on chemical safety to the 2002 World Summit on Sustainable Development in Johannesburg, at which the concept of the precautionary principle was introduced. There, it was agreed to aim, by 2020, to use and produce chemicals in ways that minimize significant adverse effects on human health and the environment.

Certainly we've had fair warning of what was ahead. Fast forward to today, and the rising tide of substance regulation threatens to engulf us all. To wit:

* South Korea is amending its Toxic Chemical Control Law, and moving toward a list of substances of very high concern (SVHC).

* China is expanding the scope of its REACH-like list, going so far as to apply tests to chemicals under R&D--in other words, products for which there may not even be a market. Its scope will include all electronics equipment. However, self-declaration is permitted, and mandatory testing is no longer in effect. Stricter limits are ahead for wastewater and air emissions, although China has traditionally done a poor job of ensuring compliance.

* Taiwan's new chemical management program goes into effect next year, although some analysts, Dripps included, believe that deadline will slip.

* Malaysia's proposed laws closely resemble REACH, but implementation is being delayed.

* Japan's CSCL is migrating toward REACH, with phase-ins coming this year and next. Japan will ban some plating bath additives such as chromate and permanganate.

* Canada's "short list" has 4,300 substances...

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