Chemical Policy Development
We have established an excellent reputation in chemicals policy and chemicals risk management. This started in the 1990s with work under the Existing Substances Regulation (ESR) (now superseded by REACH) on behalf of the UK and other European Governments. It progressed to analysis of the socio-economic advantages and drawbacks of legislation on the control of risks from chemicals to human health and the environment on behalf of the European Commission. Our team prepared a landmark guidance document on the application of socio-economic analysis to chemical risk management issues on behalf of the OECD.
Since its inception in the 2000s, the REACH Regulation revolutionised the way chemical risks management is undertaken in the EU, and this created an environment for similar legislative frameworks to develop in other global regions. We have been involved in REACH from its conception, by undertaking the main Business Impact Assessment for both DG Enterprise and DG Environment on the then draft Regulation, and continued into the development of Guidance documents for the implementation of REACH.
Following UK’s withdrawal from the European Union, we have worked in several Defra (UK Department of food and rural affairs) and BEIS (Department for Business, Energy & Industrial Strategy, (since 2023 split into Department for Energy Security and Net Zero, Department for Science, Innovation and Technology, and Department for Business and Trade)) projects to support the transition to UK REACH.
Since the early 2000s, we have been involved in the formative stages of various pieces of other highly significant environmental legislation including the Water Framework Directive and the Biocidal Products Regulation. We are actively working on several aspects of REACH, mainly Authorisation and Restriction, and the development of guidance and methodology for a range of clients, within both the private and public sector. However, as the REACH Regulation incorporates several requirements for the European Commission to review progress and impacts and also consider the need for revisions to the requirements (for example in relation to 1-10 tonnes substances), our work for the Commission in relation to the refinement of REACH continues, where we have also supported work on Endocrine Disruptors.
Together with RPA Europe we have assessed the chemical regulatory preparedness and national capacity of seven EU Candidate Countries covering REACH, CLP, BPR, POPs and PIC in projects supported by ECHA. We have recently been involved in several projects for the European Commission and ECHA in relation to the safety of nanomaterials.
RPA’s expertise includes an interdisciplinary combination of chemistry, chemical engineering, environmental science, toxicology and economics. RPA has developed tried and tested quantitative and semi-quantitative risk-based approaches to a very wide range of situations, hazards and risks.
Where appropriate, we have forged strategic alliances with providers of expertise in specific fields of chemical risk assessment and management which allow us to offer a wide breadth of services in several areas.
In the area of chemicals policy development, RPA is capably placed to:
- Assess the economic and social impacts of proposed regulatory interventions and policies, as well as evaluate the impact that past legislation has had on the control of chemical risks and the functioning of the internal market
- Support public authorities in preparing justified and robustly costed proposals for restricting the placing on the market and use of chemical substances in specific applications in the EU and beyond
- Prepare risk assessments according to REACH guidelines either for industry or public authorities, for example as part of a REACH compliance strategy (Authorisation and Restriction)
- Collect, synthesise and analyse information on market structures, flows of chemicals, and articles containing them, into and out of the EU, and provide strategic advice on competition dynamics and the competitiveness of specific chemical industry sectors
- Review studies undertaken by authorities, industry and consultants to ensure that they have been appropriately conducted and adequately reported to an equivalent standard in line with prevailing guidance and existing assessment methodologies
RPA’s work on chemicals is interlinked with work on Governmental (EU, UK, National) enterprise and industrial policy, as we take a holistic view of the potential socio-economic impacts of regulatory intervention on specific industrial sectors and markets in the EU and UK (and often beyond), along with the safety, market availability, quality and cost of consumer products.