Fourthly, the following report looks at prioritisation of various hazardous substances reviewed by HSE:
It seems that CPSA may have further work to do. I note this as "Proposals not considered a priority in 2023/24":
14.
Description of proposal
Proposal to restrict the placing on the market and use of substances containing PAHs in clay targets for shooting.
Primary hazards
Carcinogenic, PBT and vPvB.
Rationale
Clay targets (also known as clay pigeons) are produced using binders such as coal tar pitch high temperature (CTPHT), petroleum pitch and other types of resins. They are commonly used by sports shooters and small game hunters to practise. During use, these substances can be emitted into the environment, while the collecting of the targets can lead to human exposure.
CTPHT is on Annex XIV of both EU and UK REACH, but authorisation does not apply to the placing on the market of substances in articles, so imports of clays containing CTPHT continue to be permitted.
In July 2021, the European Commission requested that ECHA prepare an
Annex XV restriction dossier on substances containing PAHs in clay targets. ECHA proposed to restrict the placing on the market of clay targets containing more than 0.005% by weight of the sum of the concentrations of 18 indicator PAHs, to prevent the import of clays containing CTPHT. A joint opinion by the RAC and SEAC was sent to the European Commission in December 2022 in support of the proposed restriction, which included a 1-year transition period with a 1% concentration limit. The European Commission has not yet decided whether to include the proposed restriction in Annex XVII of the EU REACH Regulation.
The International Sports Shooting Federation already limits PAHs in clay targets for international events such as the Olympics, so the targets used in these events would already be compliant with this proposed restriction. Alternatives with very low or no PAH-content are available, and the UK is a major producer of eco-clay targets, free from CTPHT.
HSE has not received any authorisation applications for CTPHT, which means that it is not legally used in Great Britain for the manufacturing of clays. It has not received any notifications of substances in articles that would indicate imports in large volumes. Any potential imports of clays containing CTPHT are therefore currently limited to volumes under 1 tonne per importer per year, or in concentrations below 0.1% weight for weight.
We will continue to monitor notifications of substances in articles to identify any change in import trends and consider the potential benefits of introducing a restriction in future work programmes.
Also, re lead, these, again "Not a priority in 2023/24"
4.
Description of proposal
A proposal to address the risks to the public from lead exposure through direct contact and, predominantly, indirect environmental contact from emissions during PVC articles’ service life, treatment, and disposal as waste.
Primary hazards
Toxic to reproduction, neurotoxic.
Rationale
Lead-containing compounds can be used to stabilise PVC. However, the European PVC industry has voluntarily phased out the use of lead in PVC (read more detail on this measure in the
VinylPlus Progress Report 2021).
This means that since 2015, virgin PVC produced in the EU (and the UK) should not contain lead. This restriction would only affect imports of lead-containing PVC from outside the EU.
In 2016, a proposal was submitted under EU REACH to
restrict the use of lead compounds in finished articles produced from polymers or co-polymers of PVC. However, the European Parliament vetoed the proposal in 2020, which required the EU Commission to submit a revised proposal.
The RAC opinion on the proposal concluded that PVC is a minor source of indirect exposure to lead via the environment, when compared with other sources such as lead shot (HSE have recently
published a restriction dossier on lead in ammunition). The EU also identified a potential restriction on PVC and its additives in the
Restrictions Roadmap under the Chemicals Strategy for Sustainability. In May 2023 the European Commission decided to include the proposed restriction in Annex XVII of the EU REACH Regulation.
In September 2022 the Environment Agency commissioned a report on additives in PVC to further understand the potential risks to the environment and human health in Great Britain. The evidence gathered will be used to inform the appropriate authorities on the potential issues which may arise from the use of PVC additives, including lead compounds.
11.
Description of proposal
A proposal to investigate the risks of using lead in fishing weights and consider if a UK REACH restriction is required through an RMOA.
Primary hazards
Toxic to wildlife by ingestion.
Rationale
Fishing weights were historically made from lead because it is readily available, inexpensive, dense and easily mouldable. However, lead is also highly toxic to both human health and wildlife.
In 2019, a
proposal was submitted under EU REACH to restrict the use of lead in fishing sinkers and lures as part of a restriction on the use of lead in projectiles. In 2022 RAC and SEAC concluded that restriction is the most appropriate measure to address the identified risks. The European Commission has not yet decided whether to include the proposed restriction in Annex XVII of the EU REACH Regulation.
The prioritisation exercise therefore considered proposals to introduce additional measures on lead fishing weights. Lead fishing weights are not within scope of the proposed restriction on lead in ammunition under UK REACH.
However, lead fishing weights between 0.06g and 28.35g were banned in England in 1986 (similar regulations apply in Wales and Scotland) and the
evidence suggests that this ban has addressed the concern. Therefore, this is not a priority for action under UK REACH this year. However, the potential benefits of a restriction under UK REACH to address any uses relevant to fishing that fall outside the scope of the existing bans in Great Britain will be reconsidered when setting priorities in future years.
