Panel 1: How to choose the best possible risk management option to regulate substances of very high concern

1. How to Decide on the Most
Appropriate Regulatory Management
Option…
Helsinki Chemicals Forum 2019
…”The best option for
regulation is determined by
policy decision.”
…”Industry can make a
difference: informed
decision making leads to
better risk management.”
…”Maximum understanding
doesn’t imply optimum risk
management.” Fleur van Broekhuizen
RIVM/Bureau REACH
The Netherlands

2. What can we learn?
2
Uncertainties
play a key
role
Appropriate
RMO?:
Perspective
matters
There are
key
principles
Helsinki Chemicals Forum 2019

3. Different legislative options, e.g.
Helsinki Chemicals Forum 20193
REACH
OSH
Cosmetics
IED
BPR
PPPR
FCMD
Waste FD
Water FD
…
End-of-pipe
oriented
Source
oriented
EU / W-W
implementation
National
implementation

4. The NMP-case
4
REACH-Annex XIV
- SVHC (art.57c)
- Incentive for substitution
- Industry to apply for
authorization and show
safe use
- Case-by-case assessment
of safe use conditions
- Would address all uses of
NMP
REACH-Annex XVII
- 1 restriction versus many
applications for
authorization
- Targeted on the risks
observed
- Hazard is a threshold effect
- Safe use is possible
- Substitution did already
take place as far as possible
- Mandatory DNEL for
inhalation and dermal
exposure
- Prescribed safe use practice
- Alternatives are of
comparable concern
OSH
- Protection of worker health during
all process steps; also waste phase
- STOP-principle
- OELs for inhalation & Skin notation
- bOELs versus iOELS
Helsinki Chemicals Forum 2019

5. Helsinki Chemicals Forum 2019
…”The best option for
regulation is determined by
policy decision.”
…”Industry can make a
difference: informed
decision making leads to
better risk management.”
…”Maximum understanding
doesn’t imply optimum risk
management.”
…There is not just one way
to Rome and ideas about
the preferred way may
change with time
…Information on hazard,
exposure and uses is key
…In case of a (very) high
concern, precaution is an
important element of the
decision making process