Socio-economic analysis in REACH restriction dossiers for chemicals management: A critical review

Can "Hazard-Cost-Effectiveness Analysis" improve the risk management of chemicals under REACH?

Cost-Effectiveness Analysis (CEA) is a decision-making framework to prioritize policy decisions for chemicals. Differences in hazard profiles among chemicals are not integrated in CEA under the EU REACH Regulation, which could limit its relevance. Another concern is that two different economic decision support methods (CEA for chemicals considered as PBTs or vPvBs from a regulatory perspective and Cost Benefit Analysis (CBA) for others) are used under REACH. To address this situation, we define "Hazard" CEA by integrating a hazard score, based on persistence, bioaccumulation and (eco)toxicity, in the effect indicator of CEA. We test different designs and parameterizations of Hazard-CEA on a set of past socio-economic assessments under REACH for PBT and non-PBT chemicals. Weighing and thresholds in hazard scores do not have a significant impact on the outcome of Hazard-CEA but the design of the hazard scoring method does. We suggest using an integrated and unweighted scoring method with a multiplicative formulation based on the notion of risk. Hazard-CEA could be used for both PBT and non-PBT chemicals, to use a single method in REACH and therefore improve consistency in policy decisions. Our work also suggests that using Hazard-CEA could help make decision easier.

Choosing the best for preventing the worst: A structured analysis of the selection of risk management options in REACH restriction dossiers

Under the European chemicals legislation REACH (Registration, Evaluation, Authorisation and restriction of CHemicals), the use of chemicals posing an unacceptable risk for humans and the environment can be restricted. This requires that regulatory authorities of EU member states, or the European Chemicals Agency on request of the Commission, submit a restriction proposal in which they suggest one or multiple risk management options (RMOs). The options are recommended to be evaluated in a socio-economic analysis (SEA) using defined criteria. This paper explores the drivers of the selection of the preferred RMO in 32 restriction dossiers. Applying principal component analysis reveals that the selection of the preferred RMO, and the evaluation of possible trade-offs between alternative RMOs, is determined by criteria characterizing a measure's effectiveness and practicality, in particular its risk reduction capacity (R) and proportionality. A logistic regression using quantitative estimates provided in SEA suggests that the probability for an RMO to be selected is the higher the higher its R and the lower the costs of the restriction. Based on our analysis we conclude that the selection process of RMOs in REACH restriction dossiers could be strengthened by defining a limited but unambiguous set of criteria, conducting a score-based evaluation as a default, and by defining transparent decision rules.