I, David Brown, am a regulatory environmental scientist with several years of experience working for an international oil company. I have a detailed understanding of chmical risk assessment and have supported a number of high-profile projects. This was my first visit to SETAC (Society of Environmental Toxicology and Chemistry), an annual conference where academia, industry, government and non-profit organisations gather to discuss the sustainable use of chemicals and how to reduce their impacts to humans and the environment. I was very interested to learn about the leading-edge science that eventually trickles down and influences chemical regulatory frameworks such as REACH and CLP.
This conference covered a lot of ground. There were sessions on microplastics and nanomaterials, sustainable chemistry, endocrine disruptors, emerging contaminants and all manner of presentations on experiments that assessed the hazards of chemicals.
Strategies to develop and use alternative, less harmful chemicals and substances were described in several presentations. Most strategies included the use of modelling to find greener alternatives that are more likely to pass regulatory testing and will be less harmful to humans and the environment. Another major component of this effort is the use of life cycle analysis (LCA) to understand the holistic benefit of using another chemical. Ricardo consultants have been performing LCA studies for many years covering a large breadth of products. These will become increasingly important as REACH moves towards the next stage of its implementation where replacement of high-risk chemicals is needed.
Chemical risk assessment has developed over the years and is now an incredibly complex and multi-faceted science. The many approaches being used have generally been optimised for assessment of mono constituent chemicals (i.e. single chemicals). There is a growing realisation that many of these approaches and the associated regulation may not be suitable for multi-constituent substances such as UVCBs (substances of unknown or variable composition, complex reaction products or biological materials). Two whole sessions at the conference were dedicated to risk assessment approaches for UVCBs. Considering these make up for more than 20% of chemical registrations under REACH, there is potential opportunity for different industry groups to learn from each other and develop top tier solutions for assessing and determining risks of UVCBs.
Some work coming out of a CEFIC-LRI project led by the Danish Technical University, suggest some alternate approaches for risk assessment of UVCBs and mixture substances. Our very own Chris Hughes (Principal regulatory consultant at NCEC) presented a piece on the impact of bioavailability (the fraction of a substance available) on the persistence of chemicals in the environment. His presentation spoke about some of the limitations of current testing and assessment approaches prescribed under REACH. Being part of and influencing such a large and impactful regulatory framework, such as REACH, speaks volumes of Chris’ and NCEC’s (Part of Ricardo) work in this field.
One of the key objectives of chemical risk assessment is the reduction of experimental testing. Efforts are being made to assimilate the huge amount of data generated from historical experiments of chemicals and create models and tools, known as QSARs (Quantitative Structure Activity Relationships), that can help with the assessment of new chemicals. A whole day was spent learning about how these tools should be used in a regulatory context such as REACH. The really great thing about this all-day session was hearing first-hand from the regulators (European Chemicals Agency, ECHA) what they expect when modelling data is presented to them. I think the use of modelling can be a powerful tool to help with chemical assessment and these tools will only get better as high-performance computing becomes commoditised.
The Executive Director of ECHA, Bjorn Hansen – who has been on the scene for more than 20 years, developing and overseeing the progress of REACH implementation – gave a keynote speech about the intentions of the REACH regulatory framework. This included discussion of the additional responsibilities ECHA is taking on with respect to the Waste Framework Directive, which are intended to accelerate progress towards the broader circular economy goals of the European Union. Ricardo has already helped reduce UK’s annual CO2 emissions by 3.1 million tonnes and are at the forefront of the procurement of the new waste services. His presentation resonated with me because he highlighted one important fact about all sciences – it comes with bias, unintentional or otherwise. It is important that this bias is challenged, corrected and minimised to ensure that regulatory frameworks are implemented in the fairest way possible. Engagement will be key to ensuring that this happens. An example of where this bias can have an effect is the proposed socio-economic calculations used for exemptions during the use of dangerous chemicals. A large discrepancy was observed between industry perceived benefits and those identified by regulators.
My understanding from the conference is that there is a lot of work now needed on the side of the regulators to review and provide feedback regarding dossier submissions. In the next 10 years, ECHA hopes to complete their assessment on REACH dossiers and it will be interesting to see how this process will be implemented. We at NCEC provide a comprehensive range of REACH services such as the creation of dossiers and submitting registrations and are continuing to evolve and improve our process as the assessment process changes.
Overall this was a very interesting and information rich conference. It reinforced the concept that chemical risk science is a very dynamic field of study. I was also encouraged by the openness of people to listen and discuss differences of opinion in a friendly manner. It will be interesting to see where environmental science takes us in the next few years and how regulatory frameworks, such as REACH, adapt to new information.