ECHA issues a draft of its first Community Rolling Action Plan for substance evaluation

ECHA delivered its homework on time by releasing, before its December 1st 2011 deadline imposed by REACH, a draft for a first Community Rolling Action Plan ("CoRAP") for prioritised substances for the years 2012, 2013 & 2014.

The draft introduces 91 substances to be evaluated and is also published on ECHA's website in order to keep stakeholders informed.

What is CoRAP exactly?

Substance evaluation is one of the 3 types of evaluation processes under REACH, testing proposals evaluation and compliance checks being the other two. The process commences with the identification and prioritisation of registered substances where the registration data was not sufficient to conclude whethera risk does or does not exist for human health or the environment. As the process is handled by both ECHA and the Member States, the selection and prioritisation is therefore not only based on risk criteria like hazard and exposure information as well as available tonnage but can also include paying regard to national priorities.

What is its impact on the market?

The evaluation exercise can lead to, firstly, a decision requesting further information which is sent to the registrants or, secondly, a report with the member state’s conclusions which is then sent to ECHA. The identified risk can ultimately be addressed through the REACH processes of authorisation, restriction or harmonised classification and labelling.

From the draft list…

A draft plan is prepared in close cooperation with the Member States. ECHA submits the draft to the Member State Competent Authorities and the ECHA Member State Committee. The Committee prepares an opinion which enables ECHA to adopt a final version of the CoRAP. The process does not include a public consultation but ECHA informs the stakeholders of the progress made by publishing the draft list of substances with specific but limited information.

…to the "final" plan for 3 years

A finalised CoRAP stretches over a period of 3 years.
The substances subject to immediate evaluation are listed for the first year of the plan.
The content of the program is flexible to some extent: after the first year, the plan can be updated to include substances for the additional year as well as any revision to the substances that were included in the second and third year of the original plan. Throughout the whole action plan, a Member State may even notify at any time that it has information suggesting that a substance is a priority for evaluation, even though it is not included in the CoRAP list: in these situations, the CoRAP may be amended to include this substance prior to an annual update.
Therefore, the total number of the substances to be evaluated in 2012, 2013 and 2014 could eventually be (much) higher then the initial scheduled 91 items.

Where do we stand in the current CoRAP procedure?

•The draft plan was submitted to the Member States and the ECHA Member State Committee in October 2011.
•The Committee will, or aims to, prepare an opinion on the draft CoRAP for February 2012.
•By the end of that month, ECHA should adopt the final version which will indicate the Member State responsible for the evaluation and in broad terms the initial reasons of concern.
•The respective Member States have one year to evaluate substances specified for 2012 and, where regarded as necessary, to prepare a draft decision for requesting further information to clarify the suspected risks. Registrants of substances listed on the final CoRAP will be provided with an opportunity to comment before any final decision to request further information is taken.
•A first update is scheduled for 2013.
•ECHA will submit draft annual updates to the CoRAP and to the Member States by 28 February of each year.