On September 5, 2017, ECHA – European Chemicals Agency, the governing body behind REACH – announced they were accepting public consultation to help identify nine new potential Substances of Very High Concern (SVHC) to add to the Candidate List. (Well, that’s not entirely true, eight were new, and one was to update information.) That consultation period closed in mid-October.
Seven additions and one update were formally announced on January 15, bringing the Candidate List to 181 items.
The big surprise for me was the number of chemicals under consideration; after the July 2017 update added one new substance and expanded a second. I was anticipating a small list, and I still expect future lists only to feature a handful of chemicals.
Bisphenol-A has been present – one add, one update – in the last two additions to SVHC under different categories, so the latest update is breaking no new ground (which now also lists it as having endocrine disrupting properties).
Of the seven new additions, two chemicals – benz(a)anthracene and chrysene – are currently listed in the California Proposition 65 legislature. (Proposition 65 is legislation designed to identify chemicals the State of California has recognized as being cancer-causing or toxic to reproduction.) A quick note: Bisphenol-A is also in Proposition 65.
The ECHA notes that benz(a)anthracene and chrysene are not registered substances under REACH, as they are not normally produced, but occur as constituents or impurities in other substances. If either substance were present in thermoplastic resins, even at levels well under the No Significant Risk Level (NSRL), producers most likely would have declared these were present anyway, because to not make any declaration under Prop 65 tends to be riskier.
One addition to the Candidate List that our industry may have been worried about is Dechlorane plus, a non-plasticizing flame retardant. However, there have already been studies about the potential hazard this substance may cause, including discussion leaning towards listing it as a persistent organic pollutant by the United Nations Stockholm Convention.
Only one of the nine substances in the public consultation didn’t make the cut (at least not this time) – tricobalt tetrachloride containing ≥ 0.1% w/w nickel oxides. If it ever makes the Candidate List, it should prove easily addressable by any statement from a producer which says they do not use nickel or compounds including nickel in the formulation of their materials. (We’ll discover in March or April whether they try again to add it, as that is when the next public consultation period opens.)
We have been working with our suppliers to get updated SVHC statements, and will gladly provide them to our customers upon request.
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