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Validity of REACH risk limits in the Dutch policy framework on priority chemicals : Road-map Quality standard setting

Bruikbaarheid van REACH-risicogrenzen in het Nederlandse prioritaire stoffenbeleid


REACH is the European policy framework for the risk management of dangerous chemicals. Producers and importers provide risk limits below which the use of a chemical is assumed to be safe. For efficiency reasons national authorities want to use the REACH data as much as possible when executing the Dutch policy on priority chemicals. The policy goal is that the environmental concentrations of priority substances, for example chemicals causing cancer, in the Netherlands should be below the negligible (risk) concentration in 2030. RIVM investigated the validity of REACH data in the Dutch policy framework on priority chemicals. The research was based on a sample of more than 200 chemicals. For a large number of chemicals the REACH dossiers were found not to contain risk limits. If risk limits were available, then industry relies on other figures than authorities. In most cases industry applies less stringent limits, sometimes with a substantial difference (factor of 100 or more). In those cases industry claims safe use of chemicals on values that deviate from the standards currently used by authorities to safeguard man and environment. Therefore carefulness is needed when transferring REACH risk limits to other frameworks, like the policy on priority chemicals in the Netherlands. Above-mentioned differences may be caused because REACH and authorities found risk limits on different methods. In addition, authorities may not yet have implemented certain new insights, resulting in more conservative standards. However, industry's interpretation of key data on important characteristics of a chemical may also be different. For, amongst others, local permit authorities it is important to realise that such differences and gaps may occur and that they should be further examined. RIVM gives a number of recommendations how stakeholders should handle REACH data in those cases for a better protection of man and environment. RIVM will prepare further guidance for this purpose.

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