Brussels – ISOPA and Alipa, the European associations for aromatic and aliphatic isocyanates and polyols, are calling for the EU to stop any extension of generic risk assessments that disregard exposure and use considerations, or extending them to professional uses, in a submission to the EU on the latest Reach revision.
The associations are also opposed a generic Mixture Assessment Factor. ‘This is not the right approach to solve the issue of potential unintentional combined exposure,’ the associations said.
They are also concerned about the concept of essential use, and would like to see a clear definition of the criteria that would be used to decide if something is of essential to society. The associations warn that although this is being presented as a way of speeding decisions, many exceptions are likely to be needed, and this will slow decisions down.
Calls for more information should only be generated if the information will add value to risk management. Increasing requirements should not become a barrier to innovation which could hamper the Chemicals Strategy for Sustainability, they warned. Testing should be targeted, and unnecessary animal testing must be avoided. Polymeric precursors to polymers that are used under both ‘strictly controlled’ and ‘adequately controlled’ conditions should be regulated using a risk-based approach for exemption or reduced registration, the associations said.
On the positive side, the organisations said that the way that the between Reach and OSH regulations operate is a good example of coherence and how legislation can work together properly with a Binding Occupational Exposure Limit (BOEL), which is being discussed within the EU at the moment as complementary to the existing Reach regulations.
