1. STRATEGY ON MANAGEMENT OF SUBSTANCES (SOMS)
October 2003
Jan Suurland
Counselor for Environment and Spatial Planning
Royal Netherlands Embassy in Washington en Ottawa

2. STRATEGY ON MANAGEMENT OF SUBSTANCES (SOMS)
Policy Paper (March 2001)
Introduction of new chemicals policy to deal with the wide gap in information on hazards of chemical substances and backlog of risk assessments and subsequent control measures.
Declaration of Intent Dutch Industry (April 2001)
Acknowledge responsibility industry for providing adequate information and safe handling of chemicals throughout life cycle.
Actual implementation to be harmonized within EU.

3. ESSENTIALS SOMS Quick Scans
Producers/Importers to assess hazards on the basis of available information of intrinsic properties of substances.
Public Right to Know
Industry to ensure public availability of quick scan results and other relevant information regarding the safe use of substances.
Product Chain Reponsibility
Industry responsible for prevention and risk management throughout life cycle of substances (Duty of Care).
Precautionary Principle
Industry required to take ‘in principle measures’ in conformity with the classification of substances in various levels of concern as defined by the quick scan methodology.
Balancing Risks versus Cost-Benefits
Actual implementation of ‘in principle measures’ will take into account socio-economic consequences.

4. QUICK SCAN APPROACH Objective
To use available information on intrinsic properties of all substances as a basis for decision making on the need for (additional) testing and risk assessment on the implementation of bans or other restrictions on the use of those substances.
Methodology
Development of independently verified substances profiles containing essential hazard information (P,B,T,He,C,R,M,Ho).
Application of criteria to allocate a particular substance in a specific category of concern.
Linking concern categories to use categories to identify ‘in principle measures’ to be taken.

5. General Policy Conditions for:
Site limited intermediate substances
Substances in industrial applications
Substances in consumer applications
Open professional use of substances
Substances in concern category:
Substance acceptable?
Very High Concern
No, unless No
High Concern
Yes, provided
Concern
Low Concern
Yes
No Data,

6. Very High Concern Substances
Provisional List by RIVM-CEC.
Application of quick scan methodology to high concern substances on OSPAR list.
48 out of 79 substances qualify as VHC (including 19 pesticides).
22 to be considered POP like substances (VPVB) qualifying for immediate ban (including 6 pesticides).
7 substances qualify as VHC because of insufficient data.
20 VHC substances are High Production Volume Chemicals.
NB: None of the 48 substances are yet included in current EU priorities programme for existing substances.

7. Implementation Status - SOMS
Quick Scan (Industry wait for outcome REACH).
Establishment Chemical Data Bank (Industry wait for outcome REACH).
Establishment Chemicals Expertise Center (2003).
Pilot projects product chain responsibility (7 sectors).
Implementation agreements industry (dependent on REACH).
Back stop regulation to enforce quick scans (shelved awaiting REACH).
Incorporating precautionary principle and product chain responsibility in Environmental Management Act (in progress).

8. Quick Scan as instrument for prioritization REACH?
Quick Scan (prioritization)
of substances on basis of data on hazard
and use
(measure of
exposure)
Risk Registration Evaluation Authorization Measures
assessment
prioritization
industry authorities authorities authorities authorities
REACH (EU) system (under construction) = prioritization

9. Quick Scan as instrument for prioritization REACH?
Quick Scan (prioritization) of
substances on basis of data on hazard and use
First step
Towards
Estimating
the risk of
Substances
Allocation to categories of concern on basis of hazard and use
very high
concern
high concern
low concern
Necessary/desired activities
Limited risk Measures
profile sufficient authorities
Complete risk Measures
profile if authorities and
need be substance/
product
management
by industry
No or limited Substance/
risk profile product
needed management