The ECETOC-Targeted Risk Assessment Tool for Worker Exposure Estimation in REACH Registration Dossiers of Chemical Substances-Current Developments

Review of generic scenario environmental release and occupational exposure models used in chemical risk assessment

Under the Toxic Substances Control Act (TSCA), the United States Environmental Protection Agency (USEPA) is required to determine whether a new chemical substance poses an unreasonable risk to human health or the environment before the chemical is manufactured in or imported into the United States. This manuscript provides a review of the process used to evaluate the risk associated with a chemical based on the scenarios and models used in the evaluation. Specifically, the Generic Scenarios and Emission Scenario Documents developed by the USEPA were reviewed, along with background documentation prepared by USEPA to identify the core elements of the environmental release and occupational exposure scenarios used to assess the risk of the chemical being evaluated. Additionally, this contribution provides an overview of methods used to model occupational exposures and environmental releases as part of the chemical evaluation process used in other jurisdictions, along with work being performed to improve these models. Finally, the alternative methods to evaluate occupational exposures and environmental releases that may be used as part of the decision-making process regarding a chemical are identified. The contribution provides a path forward for reducing the time required and improving the chemical evaluation of the unreasonable risk determination regarding the manufacture or import of a chemical.

Understanding the limitations and application of occupational exposure models in a REACH context

Exposure modeling plays a significant role for regulatory organizations, companies, and professionals involved in assessing and managing occupational health risks in workplaces. One context in which occupational exposure models are particularly relevant is the REACH Regulation in the European Union (Regulation (EC) No 1907/2006). This commentary describes the models for the occupational inhalation exposure assessment of chemicals within the REACH framework, their theoretical background, applications, and limitations, as well as the latest developments and priorities for model improvement. Summing up the debate, despite its relevance and importance in the context of REACH not being in question, occupational exposure modeling needs to be improved in many respects. There is a need to reach a wide consensus on several key issues (e.g., the theoretical background and the reliability of modeling tools), to consolidate and monitor model performance and regulatory acceptance, and to align practices and policies regarding exposure modeling.

Is the EU chemicals strategy for sustainability a green deal?

A fully integrated Chemicals Strategy for Sustainability (CSS) in respect of chemicals is crucial and must include: • An objective evaluation of the present situation including impacts of 'chemicals of concern' throughout their life cycle, that incorporates sustainability issues. • A framework that facilitates innovation of chemistry-based approaches to tackle each of the key sustainability issues. The EU CSS only addresses adverse impacts and mainly focusses on one aspect of risk assessment, the hazard to humans from individual industrial chemicals. The proposal removes consideration of the nature and amount of exposure, which is a critical determinant of risk. It can be presumed that this is solely to simplify, and hence speed up, regulatory decisions thereby enabling more chemicals to be assessed. The linkage of this proposed approach to address any of the major sustainability issues, such as environmental pollutants is obscure. For example, the well-recognised environmental problems caused by polymers such as plastics are not considered. The proposed change in the assessment methodology lacks any scientific justification and fails to address the sustainability issues the EU and the rest of the world are facing. The authors critically discuss a comprehensive innovative evaluation methodology for the impact of chemicals.