Global Implications of REACH and TSCA IUR
- 1. Global Implications of REACH and TSCA IUR Moving Towards Comprehensive Chemical Management Accountability Jacqueline Sibblies, PE Environmental Compliance Consulting Somerset, NJ USA 11 AIChE Spring Meeting Chicago, IL USA March 16, 2011
- 2. Presentation Outline REACHOverview TSCA IUR Overview Intent of the Regulations Effects of the Regulations on Industry Related Chemical Management Rules/Policies Industry Leaders on the Cutting Edge A New Era – Comprehensive Chemical Management
- 3. REACH Overview Registration,Evaluation, Authorization and Restriction of Chemicals The Rule – Regulation (EC) No. 1907/2006 Administrator – European Chemical Agency (ECHA) Effective – December 2006 Purpose Collect data on chemicals and establish system to optimize EHS and business operations Applicability Manufacturers, Exporters, Importers of Regulated Substance Producers, Importers of Products Containing these Substances Phase-In and EINES Substances ≥ 1, 10 and 100 metric tons per calendar year Requirements Submit registration of substances (mixtures) electronically Substance Classification, Phys/Chem. properties, Documentation of Testing, Guidance
- 4. TSCA IUR OverviewToxic Substances Control Act Inventory Update Reporting The Rule – 40 CFR 710 Subpart C ( 40 CFR 711 ) Administrator – United States Environmental Protection Agency Effective Date – December 2006 ( 2011 ) Purpose Collect data on chemicals; and identify and manage risks to people and the environment Applicability Manufacturers, importers, users and processors of regulated substances Substances on Master Inventory File – TSCA Section 8b; ≥ 25, 000 and 300,000 lbs per year Requirements Submit report for calendar year prior to reporting year Chemical Name, Classification, Quantity Manufactured and Imported for Principal Reporting Year Proposed rule requires data for all years since the last report – every 4 years
- 5. Intents of theRegulations Set in place a comprehensive chemical data collection system Obtain and make available to all stakeholders the information necessary to make informed risk management decisions when using/handling chemicals Provide incentives for manufacturers and producers incorporate safety and environmental considerations in product/process development
- 6. Effects of theRegulations on Industry Challenges Risk of confidentiality breach Cost of compliance Business to business accountability Opportunities Develop/revise internal chemical and environmental management system devise comprehensive/integrated compliance approach Reassess processes/operations - cost/benefit analysis Forge strategic global alliance(s)
- 7. Related Chemical ManagementRules/Policies  PSM (OSHA)  REACH TSCA IUR (ECHA) (USEPA)  CLP RMP (ECHA) (USEPA)  SAICM (UNEP)
- 8. Industry Leaders onthe Cutting Edge DOW Chemical Company Chemical Management Policy To achieve safe and environmentally sound chemical products Safe manufacturing, handling, distribution and disposal Principles of Chemical Management System Risk Based Screen all chemicals (new and existing Initially leverage available information Recognize shared responsibilities of each party within value chain Promote Transparency
- 9. Industry Leaders onthe Cutting Edge BASF Developed Eco-Efficiency Analysis Tool (EEA) Assess optional products and processes comprehensively Considers environmental and economic factors Environmental assessment considers product lifecycle Reveals areas for improved efficiency and performance Positive results lead to significant improved corporate image
- 10. A New Era Comprehensive Chemical Management Several national, regional and international regulations with overlapping risk assessment requirements REACH and Proposed TSCA IUR share key elements of safety and chemical testing and tracking requirements Members of the chemical industry see benefits in re-evaluating internal operations and business approach Focus on enviro-economical product development and supply chain management and accountability
- 11.