Am I the only person in this industry to find the following direct quote from the EU web site on REACH and all things associated amusing and painfully ironic at the same time?
(http://ec.europa.eu/enterprise/reach/index_en.htm)
(http://ec.europa.eu/enterprise/reach/index_en.htm)
REACH is the Regulation on Registration, Evaluation, Authorization and Restriction of Chemicals. It entered into force on 1st June 2007. It streamlines and improves the former legislative framework on chemicals of the European Union (EU).
The main aims of REACH are to improve the protection of human health and the environment from the risks that can be posed by chemicals, the promotion of alternative test methods, the free circulation of substances on the internal market and enhancing competitiveness and innovation.
REACH makes industry responsible for assessing and managing the risks posed by chemicals and providing appropriate safety information to their users. In parallel, the European Union can take additional measures on highly dangerous substances, where there is a need for complementing action at EU level.
I wonder who actually feels that it streamlines anything! The legislation is a massively convoluted set of demands on business in general with a confused and complex structure of mind blowing bureaucracy that will and is causing chaos and confusion in the industry. The document itself is 1000 pages long with 10 additional annexes for guidance! In total 4,000 pages. The aim of which is to (or have industry to) fully define 30,000 plus chemicals with a view to removing those deemed too hazardous (possibly as many as 10%).
Along with the implied threat that it will put out of business those companies that do not comply, the phrase in the second paragraph extolling the enhancement of competitiveness and innovation and the free circulation of substances on the internal market is just a joke or would be if it were funny. This legislation will inhibit innovation because of the cost of compliance, stifle competitiveness by potentially excluding the smaller companies who fail or cannot afford to comply and the only chemicals that will enjoy free circulation within the EU will be the printing inks on the miles of litigation papers that will follow full implementation of this legislation when third parties realize they are being excluded from the EU market by a bureaucratic device.
Whilst Paragraph three is a noble statement; it underestimates the current responsibility industry has under existing legislation to demonstrate the hazards and safety implications of the chemicals they sell in all quantities (not just those imported in to the EU in quantities above one tone per year) so why do we need this additional legislation? If we do need it, why does it have to be in the form currently being implemented?
All of this will affect your business; compounds and regents in common use today will become scarce or so expensive that they will drop out of use. Many companies will disappear, going out of business rather than face the costs and complexity of this process.
So how is this going to help our competitiveness on an international scale, how will this improve innovation and increase free movement of chemicals within the EU above and beyond what already pertains. Who asked these faceless and work shy (the pre-registration data base was only open during working hours and not at all at weekends. Who is doing all the work here?) Bureaucrats in Europe to impose this on us?
It certainly wasn’t the industry it’s self, perhaps it was the people of Europe. I don’t remember being asked if I thought this was a good idea. Maybe our elected representatives in Europe (who are they? I hear you all say!) felt we needed this, but in who’s interest are they really acting. How many of their constituents are going to lose their jobs as a result of this legislation. I guess they don’t really care as they get elected by the unrepresentative, undemocratic, miniscule minorities of the voting public that can be bothered to turn out in the European elections.
We the majority as a result suffer.
If you agree or disagree with the above feel free to let me have your thoughts and comments.
These comments are the personal view of Robert Russell MD of AGTC Bioproducts Ltd (http://www.agtcbioproducts.com/) and are in no way representative of the organization or any of its employers
