Trade Union Priority List
The purpose of the Trade Union Priority List is to contribute to the practical implementation of REACH, in particular the authorisation procedure by proposing substances of very high concern (SVHC) which, from a trade union perspective, should have priority for inclusion in the candidate list and potentially in the authorisation list. The European Trade Union Confederation (ETUC) took a very clear stance in favour of this reform because, by encouraging industry to develop safer substances, REACH combines increased competitiveness for European industry with improved protection of workers, consumers and the environment.
For SVHC identification, the Trade Union Priority List also takes into consideration additional inherent hazard properties not explicitly mentioned in REACH article 57 but which are considered to be of “equivalent level of concern” (i.e. covered by Article 57(f)). The chemicals considered as SVHC in the Trade Union Priority List are therefore CMRs category 1A, 1B or 2 listed in Annex VI of Regulation 1272/2008, carcinogens classified 1, 2A or 2B by IARC, PBT/vPvB substances listed in the framework of the OSPAR Convention and by the European Technical Committee on New and Existing Substances, known and suspected endocrine disruptors listed in the Community Strategy for Endocrine Disruptors, neurotoxic substances listed by Vela et al (2003) and sensitisers listed in the Annex VI of Regulation 1272/2008 and the “REACH allergens” listed by Friedhelm et al. (2006). All chemicals included in the Trade Union Priority List are High Production Volume Chemicals (HPVC) listed in ESIS (European Chemical Substances Information System) or covered by a SIEF (Substance Information Exchange Forum) publicly known by March 2010 and expected to be registered by the first registration deadline. As a consequence they also meet the criteria to be eventually prioritised in the Authorisation List. But where the union list goes further is in ranking chemicals by reference to their intrinsic (eco) toxicological properties, and identifying those that cause recognised occupational diseases at EU level.
The European Risk Ranking Method (EURAM) for ranking the HPVC by scores has been adapted to cover all chemicals considered to be SVHC. The highest score (10 points) was attributed to CMRs category 1A or 1B and the lowest (7 points) to sensitisers, neurotoxicants and suspected endocrine disruptors.
In the Trade Union’s view the most urgent SVHC to be included in the Candidate List are the ones which accumulate the criteria to be identified as SVHC and, in particular, those which according to the Commission Recommendation on Occupational Diseases are known to cause recognised work-related diseases at Community level.
The resulting Trade Union List includes 568 substances covered by 334 HPVC/SIEF entries ordered by score. 209 out of these entries are substances or groups of substances identified as causative agents for recognised occupational diseases and 63 entries are substances or group of substances that cause diseases suspected of being occupational in origin.
Although available information on occupational diseases is mentioned for each entry, the scoring is only based on the intrinsic properties of the substances (i.e. hazard driven) and does not affect the ranking. ETUC, however, suggests that occupational diseases linked to SVHC should be taken into account for both their inclusion in the Candidate List and their prioritisation in the Authorisation List.
The ETUC believes that including the union-listed chemicals in the Candidate List will allow professional users to get more information on their uses. If they are subsequently prioritised in the Authorisation List (or subject to restrictions), it would surely promote the development of safer alternatives and cut both the incidence of chemical-related occupational diseases and the attendant costs for the community, workers and industry itself.
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