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Interview of Nathalie Julien, REACH Regulatory Officer
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Nathalie, can you remind us what REACH is?
REACH is a European regulation that took effect on June 1, 2007 and introduces sweeping changes in the way chemicals manufactured in or imported into Europe are evaluated. Its ultimate goal is to better protect public health and the environment.
So it’s a good initiative?
Absolutely. It’s a real opportunity for the chemical industry and its users to improve. Chemical manufacturers have been voluntarily working for years to be responsible product stewards, individually and through international programs. REACH will solidify this drive to continuously improve what we know about substances and how they can be used safely. It will also hold users more accountable. Ultimately, the chemical industry will be better equipped to meet society’s legitimate expectations, creating more public trust in us.
What made you decide to join Arkema in 2007 to take this position focused entirely on REACH?
I started my career working for a global agrichemical company. For ten years, I was in charge of European Union approval and registration, then worked as a product stewardship officer in its French subsidiary. The experience gave me a bird’s-eye view of the strategic issues surrounding product regulation. When I came to work for Arkema, I knew that I was joining a company that was proactive about REACH. Arkema understands the challenges and stakes involved and has set aside the resources needed to handle the significant workload created by the regulation.
Is REACH an onerous burden for chemical manufacturers?
Yes, because it takes a lot of resources and expertise to prepare registration dossiers for the European Chemicals Agency (ECHA).
ECHA dossiers contain comprehensive descriptions of the physicochemical, toxicological, environmental and ecotoxicological properties of the substances and pinpoint their inherent hazards. The specifications are very detailed and sometimes prompt us to run additional tests. The risk of potential human and environmental exposure to the substance throughout its life cycle, from production through end use, is also assessed for all applications.
And your role at Arkema?
I coordinate the tasks required to prepare registration dossiers for the 70 substances for which I’m responsible. I also provide more specialized technical expertise, including skills like risk assessment. Internally, I work with my fellow experts in toxicology and ecotoxicology, the HSE officers in Arkema’s business units, the HSE officers at production sites and others as needed. I also maintain contact with HSE professsionals outside Arkema, since REACH requires chemical manufacturers to share a certain amount of information.
Aren’t there several others at Arkema who work as REACH regulatory officers?
Five of us split the 430 substances covered by REACH. I handle acrylics, PMMA, hydrogen peroxides, thiochemicals excluding amines and solvents, and functional additives excluding organic peroxides.
You mentioned opportunity and strategic stakes?
Yes, and Arkema understands this very well. Substance registration is vital for staying in the market. A parallel can be drawn with the agrichemicals sector, which has been required to comply with European Union regulations since 1991. These regulations caused major upheaval in the agrichemicals market. Of approximately 1,400 substances listed when the process began, just 400 still exist today and these belong to the companies that were able to meet the regulatory challenge.
During the first 11 years after REACH takes effect, more than 30,000 substances, accounting for most of the volume produced and marketed in the E.U., will have to be registered with ECHA.
Arkema’s 2009-2018 steps
The 430 substances Arkema has to register include:
- 160 substances produced in annual quantities of 1,000 metric tons or more and those designated as substances of very high concern (SVHC) must be registered by November 2010.
- 140 substances produced in annual quantities of 100 to 1,000 metric tons must be registered by May 2013.
- 130 substances produced in small quantities of one to 100 metric tons per year must be registered by May 2018.
In addition, 30 hazardous substances are expected to be subject to the authorization procedure. The business units affected are incorporating this requirement into their strategy and substitution programs are underway.