The Registration, Evaluation and Authorisation of Chemicals regulation, REACH, addresses the production and use of chemical substances and their potential impacts on both human health and the environment. It requires downstream users, such as the tyre and rubber industry, to promote a safe use and management of substances used in production, and to progressively substitute the most dangerous substances with safer alternatives.
ETRMA takes a proactive approach at both European and global level to establish and enhance communication between downstream users and chemical manufacturers. ETRMA experts, who have considerable experience in assessing the health and environmental impacts of substances used in the rubber compounding process, jointly worked on characterizing and controlling the use of chemicals in the rubber industry.
The continued support of ETRMA towards the implementation of REACH is extensive and includes the organisation of seminars and the drafting and distribution of several guidance documents. Furthermore, ETRMA supports the work of the European Commission, ECHA and national authorities towards a successful development of their Regulations
HEALTH AND SAFETY IN THE WORKPLACE
ETRMA has a long history of work and commitment towards health and safety at the workplace.
The latest example of this work was the industry’s support to extend an epidemiological study on the risk of cancer of workers first employed after 1975 in the rubber manufacturing industry by five years. The research, which started in 2012, resulted in the publication of three peer reviewed scientific papers in 2016 and 2017 (Boniol et al, 2016 ; Boniol et al, 2017 ; Boniol et al, 2017b). The creation of guidance documents to assist companies in maintaining safety at the workplace is also part of the longstanding work of ETRMA in this regard.
ETRMA supports the establishment of biding occupational exposure limits under the Carcinogenic and Mutagenic Directive, CMD 2004/37/EC and the Chemicals Agent Directive, CAD 98/24/EC. ETRMA continuously supports European Commission for a successful implementation of the regulatory amendments.
ETRMA presence in Cross Industry Groups
- CheMI Platform
- Global Automotive Declarable Substances List (GADSL)
- Cross-Industry Initiative (CII)
- Common Industry Group
- ACEA REACH Task Force
Established in 2003, the CheMI platform was created to represent, during the creation of REACH, the interest of those downstream users of chemicals whose major role in the supply chain is to convert substances and preparations into articles. ETRMA is one of the founding members. CheMI, represents, 18 European industry associations, approximately 400,000 companies and more than 7 million employees. CheMI has seats in the high-level groups set by the European Commission and ECHA: CARACAL (Competent Authorities for REACH and CLP), ENES (Exchange Network on Exposure Scenario) and Competent Authorities for Biocidal Products meetings.
The International Material Data System (IMDS), launched in 2000, has become the standard global reporting tool used by almost all original equipment manufacturers (OEMs). The system was designed to collect, maintain, analyse and archive information on materials used for automotive components. Over time it has been adapted to meet the obligations placed on automobile manufacturers, and thus on their suppliers, by national and international standards, laws and regulations, scientific findings and risk assessments, according to the Global Automotive Declarable Substance List (GADSL). The tyre and rubber industry has been actively involved in discussions with automotive manufacturers to ensure that the IMDS system remains workable and that the GADSL is properly updated.
The Cross-Industry Initiative (CII), is an ad-hoc coalition of nearly 60 European, national organisations and companies, of which ETRMA is part.
The CII is aimed at achieving better regulation when managing chemicals in the workplace. In particular, the initiative proposes that workplace legislation be recognised as the most effective risk management option for substances where there is a need to address a risk limited to the workplace. Its members represent manufacturers as well as downstream users of chemicals, large companies and SMEs.
Activities carried out by the CII include research and exchange of views among members, to prepare documentation and define consistent and concrete proposals with a view to streamlining chemicals management in the EU. The outcomes of this work is regularly presented to and discussed with the European Commission, other EU and national authorities, social partners and other stakeholders.
The European Rubber Chemicals Association, ERCA is a CEFIC´s sector group that gathers the major producers of rubber chemicals in Europe. The ETRMA ERCA Common Interest group, CIG, involves users and producers of rubber chemicals and helps to stream line the information across the value chain of rubber chemicals. The group´s activities includes sharing best practices on the use of chemicals and information exchange on regulatory developments.
The ACEA REACH Task Force comprises representatives of all the major vehicle manufacturers and the automotive supply chain – ETRMA is part of the task force aiming to reinforce collaboration on this area across the value chain.