New substances added to the REACH Candidate List

On 27th June 2018 ECHA has added 10 new chemical substances/mixtures to the Candidate List of substances of very high concern (SVHCs) for authorization, so it now contains 191 chemical entries. The 10 new entries are:

Three cyclic siloxanes

1. Octamethylcyclotetrasiloxane (D4)

2. Decamethylcyclopentasiloxane (D5)

3. Dodecamethylcyclohexasiloxane (D6)

Comment: Some uses of D4 and D5 are already restricted in Annex XVII entry 70, and  D6 is intended to be restricted. More info and chemical structures in the News article from 18th April 2018.

A metal

4. Lead (Pb)

Comment: Since the reason for inclusion is reprotox, and the metal as such has no such effect, lead compounds should have been added, as it is in the existing restriction in Annex XVII entry 63.

A cyclic boric acid salt

5. Disodium octaborate 

Comment: Other boric acid salts are already included in the Candidate List.

A PAH component

6. Benzo[ghi]perylene

Comment: Other PAH components are already included in the Candidate List. PAH components, other than naphthalene, have no specific uses, thus uses of single PAHs cannot be restricted. Mixtures of PAH components are generated in pyrolysis and at combustion processes and such mixtures may occur as traces in products and emissions. Occurrences of trace levels of eight other PAHs are restricted in consumer articles (Annex XVII entry 50). Since single PAH components are only traded as analytical standards, they should not be on a list of chemicals intended to be authorized.

Tricyclic hydrocarbons

7. Hydrogenated terphenyl 

Comment: The reason for inclusion of this partly hydrogenated terphenyl  in the list is vPvB. However, this complex cyclic hydrocarbon mixture, of which the structure of main substance is shown above,  is not very persistent and very bioaccumulative. Thus no reason for listing is missing.

An aliphatic diamine

8. Ethylene diamine (EDA)

A phthalic acid anhydride

9. Trimellitic anhydride (Benzene-1,2,4-tricarboxylic acid 1,2-anhydride,  (TMA).

A phthalate

10. Dicyclohexyl phthalate (DCHP)

Comment: Several other phthalates are already included in the list, and some uses in toys and child care articles are restricted as Annex XVII entries 51 and 52.

General comment:

If the candidate List has to be taken seriously, it has to be scientific sound and correct, but that is not the case here, at least for metallic lead and hydrogenated terphenyls.

All chemicals have to be handled with care but not all chemical are so hazardous that they should be restricted. That will out-wash the differences between normal chemicals and the really hazardous ones, which the authorities better should use their few resources on. For instances, hydrogenated terphenyls have been rather safe alternatives to more toxic chemicals.

It is also clear that there lacks some better overview of the overlapping EU activities on various chemicals and groups of chemicals. Various aspects of a chemical should better be communicated as an up-to-date holistic approach. Then, both experts and non-experts better can understand the context, the importance, the associations and the consequences of the activity communicated.

Above I tried to do little of that. It would be much better and easier, if ECHA makes that synthesis. On their homepage ECHA has an intro page for each substance with links, however, using these links and extracting the relevant info and get an overview require much time and also expert knowledge.

In addition, the many mistakes, misjudgments or inconsequences generally occurring in ECHA’s lists are unacceptable and could be avoided by using external expert peer reviews!

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