Introduction
Knowing best how a substance is used and where there may be risks, the industry can broaden the perspective on risk management by identifying measures not limited to the range of regulatory measures, and beyond REACH.
To enhance societal and economic value, the I-RMOa approach should not be constrained by the relatively narrow scope of a Regulatory Management Options Analysis.
Two new dimensions: The European Green Deal sheds entirely new light on the importance of a risk management measure. Next to the chemicals’ management dimension, which is the domain of the simple and integrated I-RMOa as described up to now, two new dimensions should be looked at i.e. the circular economy and the climate.
The Integrated I-RMOa performed in the context of the European Green Deal will be presented in 3 pillars:
- Pillar I: Chemicals Management only (within the REACH risk management remit including Chemicals Strategy for Sustainability)
- Pillar II: Circular Economy (European Circular Economy Action Plan…)
- Pillar III: Climate (Considering relevant aspects of European Climate Law and Climate Pact, 2030 Climate Target Plan etc.)
This can ensure that the Risk Management measure is both holistic and effective for metals and inorganics. This guidance hence starts from the REACH chemicals’ management context but additionally suggests new, complementary approaches, extending the analysis beyond a standard Regulatory Management Options Analysis. The choice of the tools will depend on the type of assessment aimed for, i.e. from the identification of data gaps, the collection of information for public consultations up to the consideration of substance and production strategies.
The I-RMOa is a logical and systematic process as shown in the following illustration with an aim to identify the best RM strategy.
We have prepared a fact sheet on how to perform an I-RMOa which you can download here.
Last page update: 4 January 2024