Dr' Cas Badenhorst

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, cant
  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.

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

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.
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 RAs 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 ?
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 (gt 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

7
New Chemicals Policy REACH 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

8
REACH Registration Evaluation
Authorisation
Substances of High concern
1 ton Producer/importer
100 ton Producer/importer
PBT CMR
CSR
CSR
gt10 t
PERMIT
PBT Persistent, Bioaccumulative and Toxic CMR
Carcinogenic, mutagenic or reprotoxic
9
CSA Process overview
10
Purpose of the CSA
11
Hazard assessment
12
Exposure assessment
13
Risk characterization and risk management
14
Reporting and Communication
15
Example of REACH work plan
16
Fulfilling CSA Requirements
17
REACHWhy is it so important for metals?

• Industry supports the principle of responsible
  care !
• REACH offers opportunity to harmonize 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

18
Implementation time line
19
Implementation of GHS
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

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/introducti
  on 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
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
• DONT UNDERESTIMATE THE COMPLEXITIES OF REACH
• Plan your resources pre-registration,
  registration, pre-SIEF and SIEF, communications,
  consortia and market communications

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.