Conferences ae always a “mixed bag” and this was the case with the REACH meeting held in Brussels on 30 September/1 October. Overall, it was worthwhile attending and I certainly learned more about how the requirements of REACH relating to occupational exposures were being implemented in practice. Some of he contributions were a little too basic, given the nature of the conference and the audience, but the majority were useful.
The key points I took away from the conference were:
- there remains a clear conflict between the requirements of REACH and occupational health and safety legislation. The objectives are the same (i.e. protecting the health of workers and others) but there are significant differences in their approaches which could potentially lead to conflicting perceptions of risk and requirements for control.
- insufficient thought was given to how the REACH requirements on hazard and exposure assessment could be applied in practice before the legislation was introduced. Companies implementing the requirements are having to develop the methodologies as they go along and the timescales are too tight to allow then to be properly validated before deadlines have to be met.
- REACH DNELs (derived no effect levels) are consistently tighter than Occupational Exposure Limits (OELs) due to the major differences in the ways they are established. This can lead to confusion and as DNELs are used in the risk assessment process to develop “risk management measures” (RMMs) it is highly likely that the REACH process will result in tighter controls being specified than those based on a risk assessment using established OELs. Although this problem has been known about for a number of years, it has still not been resolved.
- The tools needed for exposure assessment, which is required to allow RMMs to be specified, are still not fully developed and validated.
- the Advanced Reach Tool (ART) looks promising and may have wider occupational hygiene applications, but needs to be validated.
- there are a number of “first tier” exposure assessment tools (i.e. basic exposure modelling methods). A number were described during the conference. It would have been useful to see them demonstrated, using the different tools for the same substance so that their conclusions could be compared.
- modelling techniques are always going to have their limitations, and this is particularly true for the basic “first tier” models. They need to be used by people who understand exposure assessment and these limitations. Ideally they shoul only be used as part of the exposure assessment process. There is a real danger that this won’t happen in many cases and that RMMS will end up being specified by inexpeienced people using only the flawed, basic models. From what I saw at the conference the models tend to err “on the side of safety” (just like COSHH Essentials). This may mean that worker health won’t be adversely affected but it could have economic consequences for he employers and possibly damage employment.
The occupational hygiene community has the expertise to develop the methodologies, and also has the knowledge and experience to work out how the REACH process could be improved. Unfortunately, I doubt that we have sufficient “clout” to influence the powers that be on this and we are going to have to live with, and try to manage, the consequences once the Regulations start to impact on “downstream users”.