ETUC
31/03/2009

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. 

The chemicals considered as SVHC in the Trade Union Priority List are CMRs category 1, 2 or 3 listed in Annex I of Council Directive 67/548/EEC, carcinogens classified 1, 2A or 2B by IARC, PBT substances listed in the framework of the OSPAR Convention, known and suspected endocrine disruptors listed in the Community Strategy for Endocrine Disruptors (241 Kb PDF), neurotoxic substances listed by Vela et al (2003) and sensitisers listed in the Annex I of Directive 67/548/EEC.

Due to the lack of reliable data on occupational exposure to these SVHC, the high production volume has been used as a proxy for wide occupational and environmental exposure. All chemicals included in the Trade Union Priority List are High Production Volume Chemicals (HPVC) and as a consequence also meet the criteria to be eventually prioritised in the authorisation list.

But where the trade 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 1 or 2 and the lowest (7 points) to sensitisers, neurotoxicants and suspected endocrine disruptors.

In the trade union’s view the most urgent SVHC 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 306 HPVC entries ordered by score. 191 out of these entries are substances or groups of substances identified as causative agents for recognised occupational diseases and 52 entries are substances or group of substances that cause diseases suspected of being occupational in origin. In addition, all entries also listed in Annex I of Directive 67/548/EEC are flagged to facilitate the preparation of Annex XV dossiers for CMRs category 1 or 2.

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 inherent costs for the community, workers and industry itself.

Further information

* Brochure Trade Union Priority List for REACH Authorisation (590 Kb PDF)

* Frequently asked questions (FAQ; 132 Kb PDF)

* To download the Trade Union Priority List for REACH Authorisation, please click on icon below.


 Trade Union Priority List for REACH Authorisation (151 Kb, Excel file)

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Last Modification :April 7 2009.