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Dr. Cas Badenhorst Programme Manager: Material Stewardship Anglo Platinum

Technical Perspective on REACH from a South African context. Dr. Cas Badenhorst Programme Manager: Material Stewardship Anglo Platinum. REACH. EU chemicals legislation that manage the safe use of chemicals throughout their entire life cycle

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Dr. Cas Badenhorst Programme Manager: Material Stewardship Anglo Platinum

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  1. Technical Perspective on REACH from a South African context Dr. Cas Badenhorst Programme Manager: Material Stewardship Anglo Platinum

  2. REACH • EU chemicals legislation that manage the safe use of chemicals throughout their entire life cycle • System consist of four pillars: Registration, Evaluation, Authorisation and Restriction of chemicals • Apply to all substances, on their own or in preparations that are manufactured in or imported into the European Economic Area (EEA) market in quantities of 1 tonne or more per year. • SA based manufacturers – non-EU based, can’t directly pre-register or register substances, substances in a preparation or substances in articles, may appoint an EU based “Only Representative” (“OR”) to take on REACH duties. 040430-AWL-PZL-HODs

  3. REACH principles • The underlying principles of REACH: • Promoting responsible care • Leaving initiative to Industry • Introducing risk assessment and Risk based management • Requiring decisions to be taken on sound science • Recognizing the value of Socio-Economic Analysis • Increasing knowledge on impact of production and products over the product life cycle 040430-AWL-PZL-HODs

  4. The issue (1) • Worldwide interest in Chemicals management started with the RIO declaration in 1992 • The IFCS (International Forum on Chemicals safety) drove/coordinated the issue at policy level; the IOMC (International Organisation on the Management of Chemicals) at technical level • Resulted in worldwide Chemicals management programs including : • The Global Harmonised Classification and Labelling system • SAICM : Strategic Approach to Int. Chemicals Management • … Chemicals management became an issue of worldwide relevance due to free market and increasing political interest. 040430-AWL-PZL-HODs

  5. The issue (2) Different regions/organisation developed key functions/interests : • Specific countries : development of Chemicals management dossiers (Risk assessments on existing chemicals) • OECD : platform for discussion and exchange of existing national chemicals risk assessments (RA) • UN : publishing the outcome of Risk Assessments EU became over the years the main international driver in metals RA’s and chemicals management, utilising the OECD and UN mechanisms to globalise the outcome of the assessments/policies South Africa recently joint the OECD Chemicals Program and therefore agreed to respect/implement its outcome ? Q. Is the SA industry responding to this chalenge ? 040430-AWL-PZL-HODs

  6. EU-Chemicals programs3 examples explained Ni and Ni compounds Risk assessment • Regulatory initiative • Binding outcome • Covers an assessment of the hazards of Ni and Ni compounds and the risks associated with the production and use • Full life cycle perspective • REACH • New Chemicals management program under discussion; launching in 2007 • Largest ever EU program (besides agriculture) with worldwide impact : • Covering all production in the EU and import to the EU (> 1t/y) • Outcome globalised via OECD-UN • Implementation of GHS • Implementation of Worldwide agreed Hazard Classification and hazard • communication system • Initiative closely followed by non EU countries incl. SA 040430-AWL-PZL-HODs

  7. New Chemicals PolicyREACH System A single, coherent system for new and existing chemicals with the following three new elements • Registration for all substances • Evaluation for all substances • Authorisation for CHemicals • A tiered approach to «existing chemicals» with focus on high volume chemicals or chemicals of high concern 040430-AWL-PZL-HODs

  8. REACH Registration Evaluation Authorisation ≥1 ton Producer/importer ≥100 ton Producer/importer Substances of High concern PBT CMR* CSR CSR >10 t PERMIT * PBT Persistent, Bioaccumulative and Toxic CMR Carcinogenic, mutagenic or reprotoxic 040430-AWL-PZL-HODs

  9. CSA Process overview 040430-AWL-PZL-HODs

  10. Purpose of the CSA 040430-AWL-PZL-HODs

  11. Hazard assessment 040430-AWL-PZL-HODs

  12. Exposure assessment 040430-AWL-PZL-HODs

  13. Risk characterization and risk management 040430-AWL-PZL-HODs

  14. Reporting and Communication 040430-AWL-PZL-HODs

  15. Example of REACH work plan 040430-AWL-PZL-HODs

  16. Fulfilling CSA Requirements 040430-AWL-PZL-HODs

  17. REACH:Why is it so important for metals? • Industry supports the principle ofresponsible care ! • REACH offers opportunity toharmonize assessment of chemicals and products in EU/WW (anticipating GHS implementation, …) • May halt “local metal unfriendly” initiatives against metals • Determines assessment methodology and database for all major environmental policies 040430-AWL-PZL-HODs

  18. Implementation time line 040430-AWL-PZL-HODs

  19. Implementation of GHS 040430-AWL-PZL-HODs

  20. Introduction • GHS - Context • Rio, 1992 – Chapter 19 of UNCED Agenda 21 • GHS is not legally binding but commitment to implement agreed at WSSD (Johanesburg 2002) • GHS provides common basis for classification and hazard communication for transport and supply and use • GHS includes a “building block” approach to facilitate flexible implementation • GHS will not be completely “harmonised“ • Increased harmonisation and improvement over time • Living document, up-dates every 2 years 040430-AWL-PZL-HODs

  21. Status of implementation of GHS • REACH Registration and Authorisation will be based on GHS Hazard id criteria !!! • South Africa and Australia are ready to implement REACH but wait first for interpretation/introduction of major trading blocks • Europe has released CLP Regulations • Implementation activities started all over the world but coordination between “blocks” is somewhat lacking! Implementation by most countries/regions at around 2007-2008 040430-AWL-PZL-HODs

  22. Take a Pro-Active Approach • No data, no market ! • Contact EU importers to ensure they Pre-Register your substances • Contact EU downstream users to ensure they are supporting Pre-Registration by the EU importer • Assist in developing Exposure Scenarios, to ensure that your uses (current & prospective) are included • NB: To secure access, Pre-Registered substances must later be Registered • DON’T UNDERESTIMATE THE COMPLEXITIES OF REACH • Plan your resources: pre-registration, registration, pre-SIEF and SIEF, communications, consortia and market communications 040430-AWL-PZL-HODs

  23. Questions? • SA Government position? • Ownership (DMR vs DoL vs Dti vs Dept of International Relations and • Cooperation? • National Committee on Chemical Safety and Management (NCCSM) • under the Dti • Draft SA GHS Regulations under the OHSA? SANS Code. • Chemicals vs. metals? • Industry response to REACH and GHS? • REACH China, and other countries. 040430-AWL-PZL-HODs

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