March 23, 2011 by wca Staff
The assessment of waste under REACH is an interesting aspect that has to be considered when registering a substance. Since waste itself doesn’t need to be registered, many people think that waste in general is excluded from REACH. However, updated guidance released by ECHA in December 2010 makes the obligations on the registrant regarding waste much clearer. Manufacturers or importers of a substance subject to registration are obliged to take the waste life-cycle stage of the substance into account when describing the exposure scenario and performing the exposure assessment.
The waste, in which the substance may be contained, includes:
- waste from manufacture of the substance
- waste occurring as a consequence of the use of the substance
- waste formed at the end of service life or articles in which the substance is contained.
In December 2010 a new version of ECHA’s R.18 guidance on the ‘Estimation of exposure from waste life’, now called ‘Exposure scenario building and environmental release estimation for the waste life stage’, was published. The new document is more detailed and case-specific than the previous one, and almost nine times as long!
So, what is different apart from the name? The main objective of the guidance is still to provide advice on how to conduct an assessment of exposure from waste, but the recommended approach is now outlined in much greater detail.
A new approach for the exposure assessment is presented as well as default release rates to the environment for the waste streams that may be relevant. Specific sections have been added on the communication of waste-related information down the supply chain and on the interface between REACH and Waste Legislation. More information about the workflow for characterising waste streams is provided, as well as new subsections for the definition and the identification of the origins and the destinations of waste, the relevance of the various waste-stages and the type of assessment to be carried out. An innovation in the new guideline is the identification of two different assessment approaches: a generic approach if the registrant is unable to obtain specific information about the wastes generated on use or at the end of service life of articles, and a specific approach when the registrant has more detailed knowledge about the amounts and destinations of waste which should always be suitable for manufacturers, but may also be applicable to downstream uses.
So, what are you waiting for? Download the updated guidance and consider the need to update your registration dossier! wca has a great deal of experience in REACH and waste related issues and can help you in updating or creating your REACH dossier by assessing the relevance of each waste-stage of the substance you have registered or intend to register, describing adequate exposure scenarios and performing the appropriate exposure assessment and risk characterisation. We will support you with technical and strategic advice, so that the best possible solution for your needs will be reached.