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Improving REACH ETUC proposals for REGISTRATION. Werner SCHNEIDER DGB, Germany. Registration. general obligation for manufacturers and importers to obtain information on their substances and to use this knowledge to manage them safely

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Improving REACH ETUC proposals for REGISTRATION


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improving reach etuc proposals for registration

Improving REACHETUC proposals for REGISTRATION

Werner SCHNEIDERDGB, Germany

ETUC Conference on REACH - 11-12 March 2005

registration
Registration
  • general obligation for manufacturers and importers
  • to obtain information on their substances and
  • to use this knowledge to manage them safely
  • applies to 30 000 substances manufactured or imported into the EU in quantities > 1 tonne per year
  • Failure to register means that the substance cannot be manufactured or imported

ETUC Conference on REACH - 11-12 March 2005

registration deadlines
Registration Deadlines

1 - 10 t

10 - 100t

100 - 1000 t

>1000 t + CMR

>1000 t + CMR

Yr 0

Yr 0 +3

Yr 0 + 6

Yr 0 + 11

(2017+)

ETUC Conference on REACH - 11-12 March 2005

slide4

The larger the volume, the greater the amount of data to be supplied

Registration requires manufacturers and importers to submit:

  • Technical Dossier:starting at 1 tonnes per year
      • identity
      • physiochemical properties
      • toxicological data
      • ecotoxicological data
  • Chemical Safety Reports:starting at 10 tonnes per year
      • hazard classification (human health and environment)
      • PBT and vPvB assessment
      • if dangerous or a PBT or vPvB :
          • exposure assessment incl. exposure scenarios
          • risk characterisation

ETUC Conference on REACH - 11-12 March 2005

loopholes in the reach proposal
Loopholes in the REACH proposal
  • No Chemical Safety Report for 20,000 out of 30,000 substances to be registered
  • Lack of basic information in the 1-10 t range

ETUC Conference on REACH - 11-12 March 2005

etuc proposals
ETUC proposals
  • CSR for all registered substances
    • To ensure possible risks are controlled for 30 000 substances.
    • To achieve a better balance between costs and benefits.
    • To increase the synergy between REACH and OSH legislation.

ETUC Conference on REACH - 11-12 March 2005

etuc proposals1
ETUC proposals
  • Acute toxicity and biodegradability tests for substances in the 1-10 t range
    • To ensure proper classification for 20 000 low volume substances.
    • To enable very basic level for protecting workers, consumers and the environment.

ETUC Conference on REACH - 11-12 March 2005

slide8
OSOR : One Substance, One Registration
  • ETUC welcomes this proposal aimed at reducing the implementation costs to EU industry and the authorities.
  • ETUC’s precondition for supporting OSOR is that producers (manufacturers/importers) and downstream users remain fully responsible and legally liable.

ETUC Conference on REACH - 11-12 March 2005