Participants
More than 120 experts from all over Europe attended the workshop. They
were representatives of ministries and administrations, the EU-Commission,
companies, NGOs and research organisations.
List of participants
Programme
The workshop was aimed at substantiating the boundary conditions and
criteria for the application of socio-economic-analysis (SEA) according
to the new European law on chemicals. The main issue was how to conduct
a SEA according to the REACH-Regulation. With this purpose in mind, the
conference provided a basis for an exchange of experience regarding methodologies,
procedures and criteria. It also offered an opportunity to discuss how
socio-economic criteria might be weighted.
Programme
Welcome and introduction
by Astrid Klug, Parliamentary
State Secretary in the Ministry for the Environment, Nature Conservation
and Nuclear
Safety, Germany
The statement outlines the fundamental changes REACH implies for the
legal system on chemicals. It also describes the role of socio-economic
analysis under the regime of REACH and the goals of the workshop.
Summary
Statement
Introductory Presentation
on SEA under REACH
by Sebastian
Gil, European Commission, DG Environment
In his presentation, Sebastian Gil describes the socio-economic analysis
in the authorisation and restriction procedures of the REACH-Regulation.
Summary
Presentation
Technical Guidance Document on carrying out a SEA under REACH:
Report on preliminary study – RIP 3.9-1
by Meg Postle,
Risk and Policy Analysts (RPA), United Kingdom
In her presentation, Meg Postle reports on the results of the preliminary
study on a Technical Guidance Document on carrying out a SEA, the REACH
Implementation Project (RIP) 3.9 -1.
Summary
Presentation
Technical Guidance Document on carrying out a SEA under REACH:
Report on the status of the subsequent project – RIP 3.9.-2
by
Michael Sorensen, Entec UK, Ltd., United Kingdom
In his presentation, Michael Sorenson reports on the status of the Technical
Guidance Document on carrying out a SEA in REACH Implementation Project
(RIP) 3.9.-2.
Summary
Presentation
Technical Guidance Document on carrying out a SEA under REACH:
Comment on the methodical approach in RIP 3.9.-1
by Carl
Otto Gensch, Institute for Applied Ecology (Öko-Institut), Germany
This presentation describes which existing and standardised methods
can be adopted for the realisation of a SEA under REACH. It also discusses
which fundamental procedural rules will be necessary.
Summary
Presentation
Annex F of the Stockholm Convention on Persistent Organic Pollutants
(POPs) on socio-economic considerations
by Reiner Arndt, Ministry
for the Environment, Nature Conversation and Nuclear Safety, Germany
In his presentation, Reiner Arndt illustrates the use of SEA in the
context of the Stockholm Convention on Persistent Organic Pollutants
(POPs).
Summary
Presentation
SEA in risk-reduction in the Existing Substances Regulation
by
Eliisa Irpola, Finnish Environment Institute (SYKE), Finland
The presentation describes the use of socio-economic analysis in the
Existing Substances Regulation and examines which elements of the corresponding
Technical Guidance Document should be carried forward to REACH.
Summary
Presentation
SEA in national decision-making regarding chemicals:
A Swedish perspective
by Åsa Thors, Swedish Chemicals
Agency (KemI), Sweden
The presentation reports on the Swedish experience of socio-economic
analysis with national decision-making regarding chemicals.
Summary
Presentation
SEA in national decision-making regarding chemicals:
A UK perspective
by John Roberts, Department for Environment,
Food and Rural Affairs (Defra), United Kingdom
In his presentation, John Roberts talks about the experience the United
Kingdom has of using socio-economic analysis as part of the work on regulating
chemicals and how that experience might be helpful in preparing for REACH.
Summary
Presentation
Industry perspective of SEA under REACH
by René van
Sloten, European Chemical Industry Council (CEFIC), Belgium
The presentation describes the role of socio-economic analysis under
REACH from the perspective of industry. It also enumerates the key criteria
for industry und comments on RIP 3.9-1.
Summary
Presentation
Eco-efficiency analysis and SEEbalance
by Peter Saling,
BASF, Germany
In his presentation, Peter Saling introduces the method known as SEEbalance,
developed by the University of Karlsruhe, the University of Jena, Öko-Institut
e.V. and BASF with support from the German Federal Ministry of Education
and Research
Summary
Presentation
The SubChem project (sustainable substitution of hazardous
chemicals)
by Lothar Lißner, Cooperation Centre Hamburg,
Germany
This presentation describes substitution regulation under REACH. It
also illustrates the deficits which substitution has shown in practice,
as well as the main factors involved in the decision whether to substitute
or not to substitute.
Summary
Presentation
SEA and substitution – lessons
from Regulation 793/73/EEC
by
Martin Frank Mogensen, Environmental Assessment Institute (IMV), Denmark
Martin Frank Mogensen presents the results of the recent report “Challenges
for economic analysis under REACH – what can we learn from previous
experience?” compiled by the Danish Environmental Assessment Institute.
The final version is to be published in spring 2007.
Summary
Presentation
Non-market values
by Lars Drake, Swedish Chemicals Agency
(KemI), (Sweden)
In his presentation, Lars Drake gives an estimate of non-market values.
He describes, inter alia, various types of non-market values and evaluation
methods and suggests some conclusions.
Summary
Presentation
During the two days of the workshop the following issues, statements and questions were referred to or discussed:
1. Methodology
• There must be flexibility and proportionality in the socio-economic
analysis.
•
The guidance should be flexible but there is also a need for good examples,
e.g. you should have answered that and that.
•
Socio-economic analysis must be practical. Simple is beautiful.
•
Socio-economic analysis is a learning process.
•
We need openness and not just fixed values.
•
The perfect studies – we have not seen them.
•
There is a need for transparency, which can be established by involving
stakeholders. In addition, there is a need for an open debate about what
can help achieve transparency.
•
Should the guidance on socio-economic analysis promote a certain method?
Or might it be better to offer flexibility in this issue?
•
The kind of methodology also depends on the information being available.
Therefore the guidance should make it clear what kind of information
is necessary to adapt the methodology.
•
We need tools and examples of life cycle analysis, which should be flexible.
•
REACH will show that there is a lack of benefit studies; universities
will take up the issue and conduct studies.
•
We need more socio and scientific research. One problem is that we mainly
consider the economic costs.
a) Boundaries of a SEA
• What are the system boundaries?
Types of impacts and effects? Geographical and time perspectives?
• It is important to define the aims of analysis before you start.
• It is necessary to focus on the main impacts. Should / could there be
a checklist for this purpose?
• Socio-economic analysis should view the whole life cycle.
• The time issue has to do with time limits. We discount the future. How
should uncertainty be addressed?
• We have to face the fact that the socio-economic analysis is a bottleneck:
Time and money are limited. Therefore we have to ask what absolutely
has to be in there.
• What is the baseline of socio-economic analysis and alternatives? Is
it the continued use of the substance?
b) Assessment of alternatives within
a SEA
• How can alternatives be identified and how should
they be assessed? For example fire retardants. One alternative is to
change the construction
standards. But it is not realistic to examine all the alternatives.
• The European Chemicals Agency will give information concerning alternatives
on its website.
• It is difficult to get information about alternatives, whether from industries
or NGOs. Some have experience in obtaining information through one to
one discussions. But this method is very time-consuming.
• Temporal impacts are important for substitutions: What could the future
technology be?
• While substitution is difficult for a single company, it is less so for
a branch. Therefore we should invite companies to work together on this
issue.
• Branch agreements are the best way for substitutions.
• How will branch-wide substitution influence socio-economic analysis?
• There are different definitions of substitution. It should not only include
technical but also organisational measures. We observe that chemicals
are increasingly replacing qualified labour, e.g. smoothing a floor by
chemicals instead of doing it by workmanship.
• How can substitution be performed? What will be the method?
c) Uncertainty
/ Lack of data
• How can we treat uncertainty in the socio-economic
analysis?
• Until now there has been a lack of data. Yet this might change as a result
of the registration procedure under REACH.
• Every sector knows a lot about its own sector. But it does not necessarily
know the health and environmental costs. No enterprise has such data.
What can we do to improve this situation?
• One way to get more information might be through a consultant as an information
broker.
• It is dangerous to rely entirely on information contributed. There are
other means to elicit information. Perhaps on the winners side.
• In the view of the chemical industry, the applicant will do the utmost
to provide the necessary information. But maybe he will not be able to
do this.
• The ideal is a full cost-benefit analysis. But in reality we learn a
lot about costs and we have to ask about the benefits.
d) Estimation of costs
and non-market values
• How can costs be assessed?
• There are short term economic costs and long term ecological and health
costs. How can you get the balance right?
• The applicant for authorisation has an interest to present his information
for socio-economic analysis in a way which is the best for him. The tendency
will be to overestimate costs. How can this meet the need for a real
picture in the socio-economic analysis process?
• It is necessary to avoid partiality.
• We should calculate in terms we already know.
• It is easer to quantify the short term costs than the long term benefits.
Is there a way to resolve this problem?
• There are various methods for quantifying health effects. But they are
all very subjective.
• How can we evaluate human health and environmental risks in a better
way? And how can we bring them into the assessment process?
• What is the price of a human being? This implies that a value for a statistical
life exists; it is an ethical question. A lot of participants of the
workshop also underlined they have problems with the statistical life
concept for different reasons.
• In the Netherlands, we have a new report concerning estimation of human
health effects. It shows that the direct health effect is not as high
as expected. But this changes if you look at the hospital costs.
• There is another problem: the eco-systems of different member states
do not have the same value. Therefore we need to standardise value.
2. Technical Guidance Document
• What level of
detail is necessary for a socio-economic analysis? And how can the need
for details be met by a general guideline?
• The existing Technical Guidance Document (TGD) should be carried into
REACH and complemented by further amendments. Though TGD is not always
best practice, it is practical reality.
• Should there be special treatment for small and medium sized enterprises?
Is the size of a company an ideal criterion? Or would it be better to
look to company earnings?
• Shall we be given specific guidelines on socio-economic analysis or merely
one general one? This question is still under discussion.
• Do case studies on socio-economic analysis already exist? The European
Commission has invited companies to come forward with case-studies. But
experience shows that nobody seeks to attract attention to certain substances.
If anybody wants to propose case-studies they can address them to the
European Commission.
3. Procedure
• Which substances should go to socio-economic
analysis?
• Stakeholders should be encouraged to take part in the consultations.
But there is no legal duty to consult stakeholders.
• When should stakeholders be consulted and introduced: at the very outset
of the socio-economic analysis or later?
• What conditions will apply to third parties giving input to socio-economic
analysis? All contributions by third parties must be considered insofar
as they contain useful information. The decision as to what is useful
might well be a political one.
• If a small or medium enterprise undergoes an authorisation procedure
and learns that a big company has already received an authorisation for
the same substance and the same use(s), will it benefit from the former
authorisation decision? If one party has been granted an authorisation
it can be shared with others. But they would have to pay a fee.
• When a company requests an authorisation, it has to communicate with
its downstream-users. What is the level of these consultations? How detailed
should these consultations be?
• What is the role of the European Chemicals Agency in the socio-economic
analysis? The Socio-Economic Committee of the Agency will conduct the
socio-economic analysis.
• If a company does not undertake a socio-economic analysis, will the Agency
do so? It is the duty of the applicant to conduct a socio-economic analysis.
If he does not do so, he weakens his own position.
• Does the Agency only assess the information they get from the applicant?
They can decide to go further. But the goal is that the applicant makes
the case with the primary responsibility being on his side.
• Who has to pay for this extra analysis performed by the Agency? It will
financed by the fees.
4. Miscellaneous
• Risk assessment and socio-economic analysis
cannot be separated.
• What is the relation between risk assessment and risk reduction?
• There should also be a set of criteria for risk perception.
• One problem of risk reduction strategies is that they examine just one
substance and one application.
• There is also a need to keep the EU-Market-Balance.
• We (the chemical industry) demand that the European Commission and NGOs
examine what is happening outside the European Union, especially concerning
products coming into the European Market from outside.
• The impact of REACH will be huge. We should not talk in terms of winners
and losers. In reality it is a moving baseline over time.
• Future generations are the winners. The losers bear the costs now.
• The total effect on the side of losers is huge yet it is not so big if
you look at just one single loser.
• Besides losers and long term winners there are also short term winners.
But they are not well organised. How can this be changed? How can the
short term winners be better organised?
• Will BASF offer SEEbalance free for all, especially for small and medium
enterprises? Yes, in principle we will make it available, but only without
the database. Experience is required to use SEEbalance. In general, it
is also doubtful whether small and medium companies have the know-how
to conduct SEE-balance.
• We do not have a legal problem, but a lack of enforcement.
• Classification leads to a label.
Concluding remarks of the
first day
by Petra Greiner, Federal
Environment Agency (UBA), Germany
In her concluding remarks, Petra Greiner underlines the need for transparency
in the preparation of socio-economic analysis. Consideration should also
be given to the situation of small companies. Still more work and research
is necessary to assess the benefits of measures. Further points which
shall be considered for future guidance on SEA-performance under REACH
include the uncertainty of the assessments, establishing “checklists” and
the need for pragmatic solutions.
Statement
Concluding remarks of the workshop
by Klaus Günter
Steinhäuser,
Federal Environment Agency (UBA), Germany
In his concluding remarks, Klaus Günter Steinhäuser summarises
the crucial questions discussed during the two days of workshops. He
makes clear that the conference has provided a number of answers, for
example concerning the information that can be expected to be submitted
by the applicants, the appropriate system boundaries, the appropriate
baseline and the flexibility of the guidance. He also describes the main
results of the discussions and some lessons learned.
Statement