What is the UK’s Rolling Action Plan?

01/06/2022

The management of dangerous goods is a serious business, and while SDS and risk assessment represent the final steps on the journey of safe handling, the evaluation data on which these steps rely needs to come from somewhere. This is where the Rolling Action Plan (RAP) comes into play.

Since the Brexit Transition Period ended on 30 December 2020, responsibility for chemical regulation in the UK has fallen to the Health and Safety Executive (HSE) in 2021 and beyond. The HSE is beholden to the UK Registration, Evaluation Authorisation, and Restriction of Chemicals (REACH) framework, in order to regulate chemicals and dangerous goods on the market in Great Britain.

UK-REACH was put into effect from 1 January 2021. EU-REACH continues to apply to Northern Ireland under the NI Protocol.

Rolling action plans are a collective endeavour to evaluate and confirm the hazards of substances that, based on risk profiles, have been determined by HSE to be a priority, with the evaluation criteria based on Article 44(1) of UK-REACH. Where data was previously lacking or incomplete, RAPs analyse human health concerns as well as environmental and ecological data to create a complete picture of potentially hazardous substances.

The current RAP put in place by HSE was published in March 2022 and will last three years. In its first year of operation, the RAP will evaluate two substances, with a total of four over the three years.

What will be evaluated

The first two substances have been chosen for evaluation in 2022, with the final two to be agreed upon in the next plan update, by 31 May 2024 at the latest. The HSE will have one year to evaluate the substances of concern once they are announced.

Paraffin waxes and Hydrocarbon waxes, chloro (Long-chain chlorinated paraffins, LCCPs)

EC number: 264-150-0, CAS number: 63449-39-8

Long-chain chlorinated paraffins are in the same chemical family as short- and medium-chain chlorinated paraffins. They are defined by a carbon number ranging from C18 to C36 and can be up to 75% chlorine by weight, compared to carbon numbers of C10-13 and C14-17 for short and medium-chain, respectively.

LCCPs are used solely in an industrial context, such as in the formulation of lubricants, rubber and polymer compounds, and metalworking fluids. They are also used in the production of flame retardants, cabling, and paper products.

There is cause for concern as LCCPs are a potential persistent organic pollutant and an ecotoxic substance, like short- and medium-chain chlorinated paraffins have been found to be. They are suspected to be Persistent, Bioaccumulative, and Toxic (PBT) or very Persistent and very Bioaccumulative (vPvB). They are also manufactured in large amounts (between 10,000 and 100,000 tonnes annually), which amplifies their concern as a persistent pollutant.

Non-chlorinated paraffins have many uses such as lubrication, insulation, candle wax, and crayons. They are not classified as persistent organic pollutants.

2,2'-diallyl-4,4'-sulfonyldiphenol (TG-SA)

EC number: 411-570-9, CAS number: 41481-66-7

TG-SA is a bisphenol used industrially in the treatment and manufacture of thermal paper. It has a high level of aggregate exposure from widespread professional and consumer use of thermal paper products, with manufacture and use at between 10 and 100 tonnes per year.

TG-SA is suspected to be an endocrine-disrupting agent, as well as having potentially reprotoxic properties. The widespread use of the substance is highly concerning, as exposure may occur in everyday workplaces or homes, affecting people when and where they least expect it.

Bisphenols are a chemical family which mimics the properties of the oestrogen hormone when consumed.

TG-SA is analogous to bisphenol S, an additive to plastics that has also been found to have endocrine-disrupting effects. Increasing regulation on bisphenols as a family of chemicals has been suggested by scientists because of their prevalence, but this is not yet ratified in legislation.

UK vs EU Action Plans

The European Chemicals Agency has its own initiative for chemical evaluation under EU REACH regulations. This is known as CoRAP, or the Community Rolling Action Plan.

Like UK’s RAP, it aims to create a complete picture of the human health, environmental risks, and exposure levels of potentially hazardous substances. Unlike the UK’s RAP, CoRAP has the means to reach out to EU member states for substance dossier data, and thus is able to evaluate many more substances in the same three-year period.

The current CoRAP is set to evaluate 27 substances over three years, assisted by the community of EU member states. Four of these are planned for a 2022 evaluation, with 14 in 2023 and nine in 2024.

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