First meeting of the reconvened OSPAR group ICG-REACH

1 November 2019

The main objective of the meeting, as agreed by OSPAR’s Offshore Industry Committee, was to progress towards OSPAR objective of harmonising OSPAR’s Harmonised Mandatory Control System (OSPAR Decision 2000/2) and the European Union regulation Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) and to solve the issue that CHARM Assessment Factors are not accepted under REACH regulation.

The meeting discussed if the scientific evidence supporting the CHARM assessment factors was suitable to support the continued use of the Assessment Factors for OSPAR approach and for submission to ECHA for consideration.

The meeting further discussed the strategy to address those substance registrations affected by non-acceptance of CHARM assessment factors under the REACH Regulation and those substances that cannot demonstrate safe use using REACH R10 Assessment Factors. The Netherlands and the United Kingdom presented studies to show how the consideration of REACH could affect their offshore chemical registrations.

The meeting considered the revision of OSPAR Decision 2005/1 amending OSPAR Decision 2000/2 on a harmonised mandatory control system for the use and reduction of the discharge of offshore chemicals to ensure that those substances registered using the OSPAR approach would be fully compliant with the REACH regulation for the end user.

The meeting agreed to adopt REACH Assessment Factor R10 in the long term as it was unlikely that it would be amended by ECHA and considering it was more conservative than the CHARM AFs. In the short-term work would be undertaken by EOSCA engaging with ECHA to identify those substances that currently may not be able to demonstrate safe use under REACH and to set a plan of action to address those substances.

The meeting agreed that the REACH ICG would consequently tackle the modification of OSPAR Decision 2000/2 (amended by 2005/1) and all underpinning Recommendations and Agreements to accomplish further harmonisation with REACH. However, the meeting decided not to change the current Risk Based Approach methodology for produced water for the next reporting cycle and keep using its Assessment Factors.