May 18, 2012 by David Taylor
Substances are now beginning to appear on the REACH Authorisation List which means that any continued use of these materials after their Sunset Date will only be possible if there is an authorisation for the specific use. In most cases, applicants for authorisations will need to submit a Socio-Economic Assessment (SEA) in support of their request, but this is currently an untested requirement about which considerable uncertainty exists.
In order to provide a forum for discussion of the many issues raised by SEA the Royal Society of Chemistry recently hosted an invited workshop at the Chemistry Centre in Burlington House on the subject “Socio-Economic Assessment for Reach Authorisation: Understanding the Issues”. The meeting, which was held under Chatham House Rules, was jointly organised by the RSC Environmental Health & Safety Committee and the UK Chemicals Stakeholder Forum on the 29th March 2012 and attended by 60 individuals from the business, regulatory and consulting communities. David Taylor, the Strategy Director of wca co-chaired the meeting with Mike Holland a wca Associate.
The meeting itself was in two parts. During the morning session participants were able to listen to a range of experts sharing their experience of how the SEA process was intended to work and how this was being borne out in practice. In the afternoon the participants split up into four workshop groups to discuss the following questions:
- Question 1: From the perspective of applicants, what are the specific difficulties that are likely to be encountered when undertaking SEA for Authorisation and how can these be overcome?
- Question 2: From the perspective of SEA practitioners, what are the specific difficulties that are likely to be encountered when undertaking SEA for Authorisation and how can these be overcome?
- Question 3: What type and breadth/depth of evidence is needed to conduct an adequate analysis of substitutes and alternatives, including their economic feasibility, in support of an SEA for Authorisation?
- Question 4: What makes a good SEA? What/how much information on costs, benefits, risks and impacts, etc is it necessary to provide to demonstrate that the benefits to society outweigh the risks?
A lively debate ensued, followed by a plenary session where output from the four groups could be considered and further discussed. A summary of the outcomes from the meeting, together with pdf’s of the presentations are available on the DEFRA website.
The main added value from the meeting came from hearing and sharing the concerns of different groups of stakholders, however a few conclusions emerged and these are shown below:
- Regulators are concerned that applicants may overly complicate SEA. The most important thing is to know the business case for applying for Authorisation on SEA grounds. There is a need to understand what will happen to the business if Authorisation is not granted before undertaking an SEA.
- Applicants should remember that they are writing the SEA for a different audience than the internal corporate audience that they may be most used to – specifically the members of SEAC. They should not therefore assume that those evaluating their application have a detailed knowledge of their products and processes.
- Regulators need to understand the difficulties in obtaining relevant data back from long value chains. It is anticipated that data collection will take more time and resources than the SEA itself.
- ECHA recognises the need to give further information to applicants and a common approach to how the Risk Assessment Committee (RAC) and Socio-Economic Analysis Committee (SEAC) work. ECHA is planning Authorisation workshops in September/ October 2012 on Analysis of Alternatives.
- This workshop served to highlight some of the key issues to be addressed in conducting socio-economic assessments for Authorisation, as well as options for taking these forward e.g. in the form of more focused debates, as well as repeating this workshop in other EU member states.
For more information on Socio-economic analysis and how wca can help please get in touch.