EDITOR ' S LETTER
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Editor : Dr Andrew Warmington editor @ specchemonline . com
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editor @ specchemonline . com JUL / AUG 2022
Endlessly moving targets
Shortly before this issue went to press , I attended ChemCon Europe , the regional version of the world ’ s largest series of conferences on global chemical regulation . Appropriately , it took place in London , capital of the country that has done more than any other to keep compliance professionals busy in recent years ... Although EU-focused , the event offered different perspectives from elsewhere in the world . One came from Sue May Teoh of Exxon Malaysia , who addressed the issues arising from the EU ’ s Chemical Strategy for Sustainability ( CSS ) and the wider challenges of increasing complexity in regulation driven mainly by the EU . Typically , Teoh said , less developed countries have simpler legislation , risk-based and targeting a few , highly hazardous chemicals . As the industry grows , regulations evolve and more information on hazards is required . This is largely done via the Globally Harmonised System ( GHS ), which itself implies the need for an inventory of chemicals actually being used and thus a notification system for new ones . The gold standard is that followed in the EU under REACH and in Canada and South Korea . This was built over 30 to 40 years . By comparison , Thailand began to implement the GHS in 2013 and building an inventory in 2015 . Other countries have not come even this far . “ Ultimately successful regulatory systems have to be built on sound science and targeted regulations ,” Teoh said . Each step has to be taken slowly , building on learnings from the ones before . Very few short cuts can be taken ; the knowledge and expertise needed to implement these regulations cannot be dropped in overnight . As yet , Teoh suggested , the CSS is not yet inspiring chemical management globally . It is still in development and is rather conceptual in nature but developing countries do tend to look at their more advanced peers when it comes to regulation and as CSS becomes part of REACH , this will surely happen . The questions are where each country is on the trend line , how much of the CSS they will adopt and how much will be appropriate for them . This raises many new challenges , Teoh said . What happens about confidential business information , or chemicals with no CAS numbers , or defining impurities ? And compiling an inventory may seem a simple thing but it is a significant challenge when doing it for the first time . If a country adopts a chemical regulation but lacks the knowledge and resources to implement it properly , many problems arise , not least testing capacity and uneven enforcement . This has been seen many times in developing countries and ultimately leads to technical trade barriers . “ For chemical management to succeed , it should be based on science , practical , achievable and suitably complex , but not too complex ,” Teoh said . “ And I think it is a moral obligation to take these things into consideration as the EU enters into negotiations with other countries .” As others observed at ChemCon , however , diagnosing the problem is not the same as solving it . The EU will not stay still on chemical regulation for 30 years so that Africa can catch up . Regulation will continue to evolve , but the consequences may include less scientific certainty and more divergence from global approaches . This is a balance that will be very hard to get right .
Dr Andrew Warmington
EDITOR – SPECIALITY CHEMICALS MAGAZINE
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