The Federal Institute for Occupational Safety and Health (BAuA) of Germany recently reviewed 398 REACH authorization applications processed by the Risk Assessment Committee (RAC) of the European Chemicals Agency (ECHA). The review revealed that in 226 cases (57%), occupational safety and health measures were inadequate. Only in 155 cases (39%) did it appear that workers were adequately protected, with no additional measures recommended.
This review revealed significant deficiencies in the implementation of occupational safety and health (OSH) measures within the REACH authorization process. Recommendations include the use of closed systems, local exhaust ventilation, protective barriers or spatial segregation, reducing the number of workers and their exposure time to hazardous substances, and improving the use of personal protective equipment.
Implemented since 2006, the REACH regulation aims to identify and control substances of very high concern (SVHC) through a multi-stage process and promote the use of safer alternatives. The authorization process involves manufacturers and importers of chemicals, downstream users, and applicants representing foreign manufacturers. When applying for authorization, RAC evaluates the risks associated with the intended use of the chemicals, the adequacy and effectiveness of operational conditions (OCs) and risk management measures (RMMs), as well as the risks of potential alternatives. According to ECHA, the three most commonly authorized substances include chromium trioxide, 4-(1,1,3,3-tetramethylbutyl)phenol ethoxylates, and sodium dichromate. Despite years of REACH regulation implementation, research on OSH remains limited.
The authorization process also specifies a review period during which authorization holders must continuously seek suitable alternative substances or technologies to reduce or eliminate dependency on SVHCs. If no alternatives are found within the review period, holders must submit a review report 18 months before the period ends, updating any changed documents and necessary monitoring arrangements.
This review underscores the need to accelerate improvements in OSH measures within the REACH authorization process, in order to enhance the safety of European workplaces handling SVHCs. It also provides a critical basis for the European Commission to consider modifications to the REACH authorization mechanism.
