Reflections on a pragmatic approach to regulatory measures addressing risk from combined exposure – REACH as an exampleRIVM-KEMI workshop
5-03-2020Steven Van de Broeck | [email protected]
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A workable methodological framework for all chemicals (COM, 2019)
• Need to have a holistic view• Retrospective and prospective action
need to go hand in hand– Retrospective actions supporting and
strengthening prospective actions – eg.advanced monitoring under the WFD
• Methodological consistency needed across EU agencies– At least on core assessment principles
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An intermediate measure?
• What is meant with an intermediate measure?– Scope and application are broad– How would one roll it out?
◦ New registrations?◦ Updates?
• Creating non-compliance situations?◦ What is assessed safe today would suddenly become unsafe?
• Once rolled out, it cannot be turned back• Consider guidance before legislation?
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Need to balance robustness and pragmatismro
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complexity regulatory response
low
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challenging straight foward
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low
highTypical research area mixture projects
MAF approach?
Are multiple layers of worst-case assumptionsstill reprentative for the real life?
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Finding a better balance … few ideas
For example:• Use & exposure patterns• Systemic vs local effects• Likelihood of co-exposure at given
time and space• Human health <> environment
Getting more focus
A tiered assessment strategy
Refinement where possible / needed
Utilise outcomes of research projects
Increased knowledge baseFor example:• Use of monitoring data• Single substances driving mixture risks• Cases where single substance
assessment need to be complemented
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We’re not yet there, but …
Let’s work together to find a balanced, structured approach beyond REACH
Knowledge has significantly increased, let’s build on it and improve it further
Perfection is not attainable, but if we chase perfection we can catch exellence
