REACh Radar Plus is a free, easy-to-use aid for chemicals management, especially in small and medium-sized companies. The Excel application enables a quick initial screening of whether chemicals are on problematic substance lists. Recently, an extension has been developed in which substance lists from companies and associations are also stored (Restricted Substance Lists). This facilitates the conformity check required by many customers.
Problematic substances
Chemicals such as chromium (VI) compounds, some plasticizers such as DEHP and the brominated flame retardant HBCDD have become subject to approval under REACh due to their problematic properties. This results in extensive substitution tasks. It is important for manufacturing companies to recognize in good time which of the substances they use are already subject to such legal restrictions or where such restrictions are to be expected. This enables an early search for substitute substances or process changes.
There are numerous lists in which such problematic substances are named. In REACh, these are in particular the candidate list, the annex of substances subject to authorization (REACh Annex XIV) and the annex of substances subject to restriction (REACh Annex XVII).
However, other lists are also interesting and important:
- For example, the European Chemicals Agency regularly publishes its work plan for substance evaluation for the next two years: the so-called Community Rolling Action Plan. It lists the chemicals that will be reviewed in the near future and for which users will have the opportunity to participate in public consultations on the substances.
- Environmental associations have drawn up their own list of problematic substances: the "Substitute it now" list. It is more comprehensive than the REACh candidate list, but is also scientifically based. To a certain extent, it allows us to look into the future. It is to be expected that the substances on this list will also be included in the REACh candidate list in the future.
- In their contracts, many companies require their suppliers to dispense with or specify certain problematic substances. These restricted substance lists (RSL) often refer to official lists, e.g. the REACh candidate list. However, they can also include many other chemicals on a company-specific basis. Some industry-specific lists are used throughout the industry (e.g. the GADSL list of car manufacturers). However, many lists are not coordinated with each other.
The number of these lists is large. The lists are updated at irregular intervals. It is therefore a considerable effort for companies to maintain an overview. The REACh Radar tool was developed a few years ago for this task and is now available as an extension.
Easy screening
REACh Radar Plus is a simple Excel application. It helps companies to quickly recognize
- whether substances used are already on the REACh candidate list or on other lists of problematic substances and
- for which substances restrictive regulatory steps are to be expected.
Figure 1 shows the basic structure of REACh Radar Plus. At its core, REACh Radar consists of a spreadsheet in which the CAS numbers of the substances used by the company are entered. The CAS numbers are then automatically compared with lists of problematic substances that are stored in separate tab sheets.
REACh Radar is easy to use. All you have to do is enter the CAS numbers of the substances used in the company in column D of the "Input" tab. This can be done, for example, using the existing data from a hazardous substance directory or a material master file via copy/paste. Listed substances are displayed automatically - if necessary for several thousand substances in one step.
Extensions in REACh Radar Plus
Fig. 2: REACh Radar Plus: Input page in the extended version The first version of REACh Radar was developed by Hansgrohe in Schiltach. It was then revised and simplified in a project funded by the German Federal Environmental Foundation (DBU). In a second project, which was completed in 2021, extensions were made to make it easier for companies to check conformity. Figure 2 shows that some lists have been added here. New additions include
- the list of persistent organic pollutants banned worldwide (POPs, Stockholm Convention)
- the list of substances named in the Explosives Ordinance
- the GADSL list of the automobile associations
- the Siemens Nixdorf list of restricted substances
- the list of substances classified as carcinogenic, mutagenic or toxic for reproduction.
The "Grouping" tab is also new. It names groups of problematic substances, e.g. problematic phthalates. The background to this is that a legally regulated substance (e.g. bisphenol A) is often replaced by a structurally very similar substance (e.g. bisphenol S). This substitute substance is not yet regulated by law. However, in many cases it also has problematic properties. It can therefore be assumed that it will also be banned or restricted in a few years' time. The problem of finding a substitute substance will then arise again. The "Grouping" worksheet compiles structurally related substances. This means that the screening shows directly if a substance used or planned as a substitute belongs to a group of problematic substances and should therefore not be used if possible. The options in REACh Radar for storing your own substance lists have also been expanded. Three tab sheets are now available for this purpose, in which CAS numbers of substances can be entered. An automatic comparison then takes place to determine whether substances entered on the input page are named on these lists. For example, companies can enter their customers' Restricted Substance Lists that are not included in REACh Radar Plus.
REACh Radar Plus is available in German and English as a free download at www.oeko.de/reach-radar and www.oeko.de/reach-radar-en
Graphics: Öko-Institut
Literature
[1] Bunke, D.; REACh Radar: Systematic identification of problematic substances. Yearbook Surface Technology 2020, Eugen G. Leuze Verlag
https://echa.europa.eu/candidate-list-table
https://echa.europa.eu/substances-restricted-under-reach
https://echa.europa.eu/list-of-substances-subject-to-pops-regulation
https://echa.europa.eu/information-on-chemicals/evaluation/community-rolling-action-plan/corap-table
