The Health and Safety Executive (HSE) recently published the UK REACH Work Programme 2022/23. The work programme sets out the activity that HSE, supported by the Environment Agency and other relevant agencies, will carry out to operate UK REACH. To complement the publication of the work programme, the Department for Environment, Food and Rural Affairs (Defra) has published the rationale used for identifying particular substances for potential regulatory action under UK REACH in 2022 to 2023. In preparation for the UK REACH Work Programme, Defra and the Welsh and Scottish governments worked closely with HSE and the Environment Agency to prioritize issues for regulatory action under UK REACH. Defra states that it used this exercise primarily to identify priorities for two types of activity in UK REACH:
- Restriction: A mechanism that can lead to controls on the use of a substance or group of substances; and
- Regulatory Management Options Analysis (RMOA): Analysis produced by HSE and/or the Environment Agency to understand the risks of using a substance, or group of substances, and make recommendations for managing them.
Defra states that it reviewed 17 proposals and identified the following five priorities for the 2022 to 2023 UK REACH work programme:
- Per- and polyfluoroalkyl substances (PFAS): Acting on the recommendations of an ongoing RMOA, due for publication in summer 2022;
- Intentionally added microplastics: An evidence project on identifying and managing the risks they pose;
- Formaldehyde and formaldehyde releasers in articles: An RMOA to review the evidence base and evaluate a potential restriction;
- Bisphenols in thermal paper: An RMOA to review the evidence base and evaluate a potential restriction; and
- Hazardous flame retardants: Reviewing and updating the existing evidence on potential environmental risks, to feed into wider chemicals policy.
The document explains the rationale Defra used to identify these priorities. It also explains why some proposals were not adopted. Defra states that it intends to reconsider these proposals when identifying priorities for future annual work programmes. Defra notes that in addition, it may identify other activities to support the aims of UK REACH, such as commissioning projects to gather more evidence.