Hi Brian
There is a UN agreement called the Strategic Approach to International Chemicals Management (SAICM), agreed February 2006 by 140 countries.....although the timescales may still vary it aims to be achieved by 2020.
Kay
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of Brian Ellis
Sent: 31 August 2006 08:44
To: [log in to unmask]
Subject: Re: [LF] REACH
Sorry, I cannot agree. The only way it would work globally is if there
were an international protocol, devised by UNEP and WHO, signed and
ratified by all countries, with sanctions against all non-signatories
forbidding signatories to import products manufactured with
non-homologated chemicals, the onus of proof being on the non-signatory.
This technique worked with the Montreal Protocol (I think ~193
signatories). You need both a carrot and a stick and everyone MUST be on
the same footing with the same timescale. The itty-bitty approach of
non-EU countries introducing different rules at different times just
wouldn't work.
I don't think the EU chemical industry will develop "greener"
substitutes, at least in the near future. Rather, it will stifle
innovation, because it will cost the industry zillions just to
homologate what they are already producing in vast quantities. The
medium-sized production (1 - 1,000 tonnes/year) will largely go by the
board in Europe as the cost will drive it to death - and many of the
chemicals our industry uses fall into this category. The smaller
speciality producers simply could not afford to homologate all their
products at €100,000 minimum per throw.
I'm very pessimistic about this. The German chemical industry foresees
losses in employment figures:
[quote]The first comprehensive study assessing the broader social and
economic effects of REACH as described in the White Paper was conducted
by Arthur D. Little for the German employers’ federation BDI. This
macro-economic study was released in November 2002 and examined the
effects of REACh on German industry. A calculation model was used with a
bottom-up approach, meaning that the effects were first assessed in
relation to specific value chains and industries and then extrapolated
to determine the overall effect on industry as a whole. Important
determinants in this study are the registration costs and the number of
expected multiple registrations. Three scenarios were developed, named
Clouds, Storm and Hurricane, resulting in gross added value loss in all
German industry sectors of 0.4%, 2.4% and 6.4% respectively, and
corresponding job losses of 150 000, 900 000 and 2 350 000. Other
anticipated effects included a considerable loss of substances from the
market, particularly products in small volumes, a loss of innovation, a
decline in investments, a fall in German exports. Overall
competitiveness and innovative capacity of German industry was expected
to diminish. [/quote]
(http://www.cefic.be/files/Publications/Appendix%204%20-%20Summary%20of%20Business%20Impact%20Assessments%20of%20New%20Chemicals%20Policy.doc)
And that is just one country :-(
Sorry!
Brian
Mike Kirschner wrote:
> Hi Brian,
>
> Just a couple points. First, I expect REACH to eventually be implemented
> more or less globally in much the same hysterical and inconsistent manner
> RoHS is rolling out globally. The Environment DG is working with China on
> their chemical policy and they're here in the US working with North American
> countries and states that have interest in such things (like California and
> Massachusetts...not Washington DC at this point).
>
> I'm not so sure it will create unemployment in the EU; your point about
> process steps moving outside the EU is a good one though. The expectation,
> and quite honestly one of the concerns I hear here in the US, is that this
> will drive the EU chemical industry to develop safer alternatives to
> existing chemicals ("green chemistry") where feasible, thus giving them a
> potential competitive advantage. In any case chemistry and chemical
> engineering might be lucrative fields for our kids to go in to if they have
> the interest. ;o)
>
> Speaking of Massachusetts, it's time for another advertisement. I think I've
> mentioned this before, but now it's germaine to the topic... The Lowell
> Center for Sustainable Production (part of the University of Massachusetts)
> is putting on short series of inexpensive seminars about REACH here in the
> US. I'm not participating but I'll attend the one in Foster City! Here's the
> link:
>
> http://www.chemicalspolicy.org/registration.shtml
>
> Mike
>
> On Wed, 30 Aug 2006 11:27:45 +0300, Brian Ellis <[log in to unmask]> wrote:
>
>> No, it's not going to be like RoHS, it's going to be far worse :-(
>> You'll see this when speciality chemicals you use are no longer
>> available because the cost of homologating them will push the price up
>> by a few hundred pounds or euros/kg, so manufacturers just won't do it.
>> The biggest effect it will have is to force European manufacturers to
>> export their processes (where the chemicals are used as a process agent
>> and do not remain in the finished product) to countries where such
>> regulations do not exist, such as the Far East or South Asia.
>>
>> As I have said before, I would welcome REACH, provided it was introduced
>> globally and not just in one economic region. This would put everyone on
>> an equal footing. As it is, it will create unemployment in many European
>> industries.
>>
>> Brian
>>
>> Paul Jackson wrote:
>>> Is REACH going to be like RoHS... what does it mean for the industry as a
> whole....?
>>> http://www.netregs.gov.uk/netregs/legislation/380525/1285481/?lang=_e
>>>
>>>
>>>
>>>
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