APPENDIX 20
Memorandum from the Whyte Group Limited
There has been comment from various MEP's that
no alternatives have been offered to REACH.
That is not the case as industry, apart from
pointing out all the failings of the proposals, has been promoting
ECETOC as a good science based risk/hazard evaluation system far
less demanding than REACH in cost and much more focused on chemicals
which should give genuine concern by virtue of their use rather
than just intrinsic hazard.
I have also suggested to Defra as have others
in Europe to their governments that a register of consumer products
confidentially listing their contained chemicals by a recognised
identification system would quickly establish which consumer products
are actually in the market place containing chemicals of concern
and that would allow the Central Agency to take the matter up
directly with the supplier rather than put the emphasis on the
chemicals producer to demonstrate and evidence through the supply
chain by a Chemicals Safety Report.
As the EU proposals are so fundamentally flawed
on cost, bureaucracy, and effectiveness, a line by line amendment
approach is undoubtedly going to lead to a hotchpotch which will
just further damage EU industry from chemical producer through
to downstream user and its competitiveness both internally and
in the export markets.
March 2004
| 
