A chemical safety assessment and its associated report (CSR) for metals and metal compounds (inorganics) requires special attention to ensure that hazard, exposure and risk assessments meet the requirements for a CSR under REACH Article 14. The major areas of concern include:
- determination of natural background levels and historical emissions since metals are known to be persistent in the environment;
- for data rich metals, the use of statistical and probabilistic tools will be required for quantifying import/export tonnage within the exposure assessment;
- speciation is of paramount importance: metals can occur in different valences, associated with different anions or cations, and can be associated to adsorptive agents, such as Dissolved Organic Matter (DOM) in water, or bound to minerals in sediment or soil. Speciation highly depends on environmental conditions and chemistry;
- the adsorption/desorption behaviour of a metal strongly depends on prevailing environmental conditions.
- differences in physicochemical properties such as (bio)availability and partitioning coefficients.
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