In the EU chemicals acquis, traditionally there have been two main approaches to risk management; one based on Specific Risk Assessment (SRA) and the other based Generic Risk Approach (GRA). Both risk assessment methods aim to ensure a high level of protection to human health and the environment, but they differ in their approach to achieve this goal.
- ‘Specific risk assessments’ consider the hazard, the use of the substances and related specific exposure scenarios for humans and the environment, and risk management measures are triggered based on their outcomes.
- ‘Generic approach to risk management’ is an automatic trigger of pre-determined risk management measures (e.g. packaging requirements, restrictions, bans, etc.) based on the hazardous properties of the chemical and generic considerations of their exposure.
The Chemicals Strategy for Sustainability announced extending the generic approach to risk management to further hazard classes (incl. Respiratory Sensitizers) and uses. This generic approach to risk management means that the procedure under Article 68(2) can be used to restrict the most harmful chemical substances in products for consumer and professional use, while allowing limited exemptions under conditions clearly defined in the law.
ISOPA does not support an extension of the approach which completely disregards exposure and use considerations, nor an extension of the GRA to professional uses. Indeed, GRA contradicts the OSH legislation by restriction even of uses that are deemed safe according to workplace risk assessment; GRA does not acknowledge education/training, organisational and technical measures implemented in line with OSH legislation.