Chemicals are essential and most import part of our lives, but also pose risk to health and safety. We are witnessing plethora of data surrounding the risk & safety of these chemicals and need for regulations. Though sometimes the shift towards highlighting the risks nullifies the significance benefits it provides to society. Such heightened awareness is because many regulatory analysts and toxicologists publish revised guidance documents on the impact of the chemicals or practices. If we investigate the history there were cases where chemicals like Asbestos is handled without proper masks and same is the case of handling many heavy metal paints studded walls. Today those are restricted activities without proper precautions. Due to this fact and many others, public and society view chemical and pharmaceutical industries with skeptical eyes. Due to these and other reasons chemical are required to be regulated in the environment. Regulations help delineate the responsibility of various stakeholders for management of chemicals.

These regulatory chemical risk control measures can be broadly classified into four categories. i. Command and Control ii. Economic iii. Incentive based and finally iv. Voluntary measures. The commonly applied approach to control of chemical risk is the control instrument. Different regulatory authorities representing state and central agencies enact different legislations to manage the risk. Regulator penalties is also another way of managing the risk like for example the introduction of carbon / chemicals tax or emitter taxes to different chemicals. Self-imposed controls or regulatory negotiated measures introduced by chemical companies is also gaining prominence in major multinational organizations to manage the risk. Such controls are being suggested right from sourcing of raw materials to the introduction of finished product to the market and final disposal.

Given that organizations intend to go for voluntary control of chemical compliance, how to go about achieving the same. It takes lot of research to generate data which can provide insights on the risk posed by different chemicals and there are multiple sources which suggest varied regulatory limits. Global Harmonization efforts are underway to bring the world regulations into conformance. UN and other Government bodies are working to bring those alignment. There is also massive effort underway in EU to compile the chemical database and risks it poses which can be particularly good benchmarking data for identifying the inherent risks of chemicals and appropriate exposures. Like GHS, REACH, other notable regulations include the Toxic Substance Control Act (TSCA), FIFRA, and OSHA regulations.

The starting point for any control mechanism is collection of sources which release such chemicals, compilation of inventory of sources is required to understand the nature of the processes which consumed different chemicals and their end use. At times we consume more than 100 different chemicals to produce a single chemical and it needs a careful analysis of the processes. Once the sources are identified it needs identification of appropriate control limits against which to bench mark the chemicals. As highlighted earlier there are various efforts underway by major organizations of the world to compile the chemical uses and exposure scenarios like the EU REACH.

Any successful control is based on how best you can measure the current levels. The calculation of the levels of the chemicals at periodic basis will help in setting up baseline levels against which one organization likes to reduce the limits. Measurement of the chemicals over a period will help identifying the trend and the reductions companies are achieved. The levels need not be only for chemical use even other mechanisms like restriction of chemicals or self-imposed prohibition of chemicals is also help organizations in gaining the confidence. These types of bench marking scenarios of self-imposed limits is very prominent for Air Quality management for Volatile Organic Compounds and other pollutants, which and can be extended to control of chemicals as well.

To conclude the concept of self-imposed control of chemicals is around for many years and it needs a robust database of impact of the chemicals and use cases where those chemicals are used. To begin companies can compile priority chemicals which poses significance risks. Further quantifying the risks associated with chemicals is also exceedingly difficult to generate and its needs massive effort from the organizations in compiling such information. The risk assessment of impact of a chemical during the life cycle of chemical use is difficult to compile. When a chemical is used in a mixture of chemicals it is difficult to compile the risk as it complicates the assessment. A robust database which can help in identifying the alternatives to existing chemicals with less potent ones and readily acceptability to different processes is also complicates such implementation. It needs more research from scientific community to compile such database across industries for use.

Many countries moved from words to deeds to meet Johannesburg goals, but for majority of countries it is yet to start. To remind 2020 is the goal for the minimization of risks of all adverse effects of chemicals within one generation. Though it might take for countries implementing chemical control regulations and compilation of such information, efforts should also start within the organizations to voluntarily compile such information. Similar support should also be extended by IT community in development of tools like Advanced REACH Tool 1.5., to carry out Operational Risk Assessment at various stages of uses and with different controls, like for example in case of REACH Exposure Assessment organizations use Excel based tools for calculation of risks. When organizations and industry bodies voluntarily compile such database and benchmarks against limits more and more societal acceptance for those companies will increase. There are already such initiatives taken up major organizations and a when more and more organizations come to the forefront it helps driving more sustainable and risk free world i.e., presumption of innocence is being replaced by presumption of guilt. A word of caution though, that without a much thought into the process can result in mismatch with country’s vision, needs, industrial structure and onerous impact on poorer manufacturers.

Thanks
Jayakumar

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