The CIA gathers industry insights through a quarterly business survey to advocate for our members’ interests with policy makers, regulators and other stakeholders.
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The chemical and pharmaceutical industry is fundamental to modern society. With an immense variety of products, from vital medicines and foods, the construction of buildings, to transport and leisure, the industry truly does have an impact on virtually every aspect of our daily lives.
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By 
Dr. Roger Pullin2024-09-23T13:44:00+01:00
Coinciding with the UK Chemicals Reactions Conference on 24 September 2024, an event organised by the Chemical Industries Association (CIA), Ramboll and Steptoe, Dr. Roger Pullin CIA’s Head of Chemical Policy and Health gives some insight into CIA’s Chemicals Management Team and their regulatory policy work.
Managing the Chemical Industries Association’s (CIA’s) Chemicals Management Policy Team, I lead the trade association’s regulatory policy advocacy work on chemicals management and workplace health topics relevant to CIA members. With over 20 years experience in chemicals policy, I work on existing and emerging UK, EU and international developments & challenges engaging with government, industry, academia, and NGO stakeholders to advise and effect solutions.
The Chemicals Management Policy Team’s expertise includes UK and EU implementation of REACH, CLP and BPR Regulations, and emerging issues whether national, European or international at the UN level. In a nutshell the Team puts advocacy into action! My colleagues Silvia Segna, Senior Chemical Policy Executive, and Kirsty Eley, Chemical Policy Executive, help deliver this along with administrative support from Rachel Nabudde.
With a new government in place, chemicals management policy topics that have been evolving slowly since the UK’s departure from the EU under the former government are now expected to move forwards. Already there has been a public consultation over the summer on the UK-REACH (Registration, Evaluation, Authorisation and restriction of Chemicals) Alternative Transition Registration model (ATRm), and more recently stakeholder engagement on proposed changes to the fees structure for UK-REACH. However, at the time of writing, there has not been any details announced by the Department of Environment and Rural Affairs (Defra) on the future direction of the Department’s policy work on chemicals both nationally and internationally.
Even though no insight has been shared with stakeholders, there remain constants in the national sense that we can take for granted such as the UK-REACH Work Programme and the Health and Safety Executive’s (HSE) work on the Great Britain (GB) Classification Labelling and Packaging Regulations. Internationally, having given funding to the United Nation’s Environment Programme (UNEP) chemicals management work and support to OECD, there is no doubt the government will continue with this work – this includes the Global Framework on Chemicals that was adopted in September 2023 and the ongoing work on both the Internationally Legally Binding Instrument Global Plastics Treaty and Science Policy Panel on Chemicals, Waste and Pollution Prevention. Also not forgetting, the UK is a signatory to international Conventions: Basel (transboundary movement of hazardous waste and their disposal); Minamata (on mercury); Stockholm (Persistent Organic Pollutants, POPs); and Rotterdam (Prior Informed Consent procedure for trade of hazardous chemicals and pesticides).
At the time of writing, it is not known if the new Secretary of State for the Department of Environment and Rural Affairs (Defra) intends for Defra civil servants to continue with their work initiated under the previous government on delivering a UK Chemicals Strategy (a commitment in 2018 within Defra’s 25-Year Environment Plan). If we are still to have a Chemicals Strategy, then in the process of its implementation the best available science should be engrained, and made use of to drive risk-based actions and decisions across both policy & regulation to support a ‘create’ & ‘make’ environment in the UK.
Back to the UK-REACH ATRm, whilst responsibility remains with industry for provision of information on chemicals to ensure a high level of human health and environment protection, the proposals from Defra aim to limit data access costs. Defra’s intention is to reduce to the essential minimum the ‘hazard’ information required for transitional registrations and intermediates, as well as ensuring that the UK authorities will receive GB-level information on use and exposure to be able to better target their regulatory work in the long term i.e. regulators’ actions will be on the issues most concerning to Great Britain.
In our response to Defra, we highlighted three key points: the importance around legality of data, the need for UK industry to remain competitive in terms of both costs & increased information requirements for new/novel chemicals, and that businesses must be given at least 24 months from adoption of legislation to understand, plan and implement the changes. Looking to UK-REACH fees, of course this will impact individual businesses differently, depending on the type of substances and volumes imported. CIA’s Chemicals Management Team also monitors the EU’s revision of EU-REACH; policy work will recommence once the European Commission is fully functional following the summer European elections. EU-REACH revision topics under consideration include information requirements (including for endocrine disrupters), a polymer notification/registration scheme, mixture assessment factors, improved use and exposure information, essential use and extension of the generic risk assessment in the context of restrictions.
Poly- and Perfluoro Alkyl Substances (PFAS) cannot go without a mention too! It is almost a given certainty that future government chemicals policy work will include the management of PFAS! In June, CIA submitted a high-level response to the Health and Safety Executive’s (HSE’s) Call for Evidence to inform a UK-REACH proposal for a restriction of PFAS use in in fire fighting foams (FFFs). Comments amongst others included the need for confidence in alternatives, importance for government to undertake a critical review of PFAS in waste to identify UK infrastructure needs, as well as need for guidance for businesses. CIA has also been proactive - in July the first meeting of CIA’s new cross industry-government initiative ‘PFAS Information Exchange Forum’ took place, providing an online meeting to exchange views, share knowledge & good practice of how PFAS is / was used in a sector and the alternatives. Additionally, CIA joined an industry editing team under Defra’s Chemicals Stakeholder Forum (CSF) PFAS Working Group that culminated in the submission during the summer of two papers to Defra, these being industry viewpoints on proposed stakeholder policy options, and a supporting information paper.
The Chemicals Management Team at CIA keeps our members informed through CIA’s communication vehicles. Weekly news emails are sent Friday afternoon’s to the Chemicals Management Network and Biocides Sector Network. In addition, monthly Microsoft Teams calls are held with the Chemicals Management Network with a focus mainly on UK REACH and GB-CLP. We also provide fora for member to voice opinions and share views on consultations and other relevant topics.
More information on CIA’s chemicals management policy work can be found on our website: https://www.cia.org.uk/about/policy-areas/chemicals-management .
Around 95% of all manufactured goods rely on some form of industrial chemical process, thus making chemistry essential to modern society and uniquely placed to address the UN Sustainable Development Goals.
