This year proved to be challenging for different UEIL committees, including the Health, Safety and Environment Committee. The committee would ideally meet three times per year allowing for personal exchange, the personal contacts that make it easier to work together in a spirit of common goals. While the lack of in-person meetings sometimes made work difficult, authorities used this time to further develop CLP and REACH decisively. The foreseeable further developments will heavily influence our business due to availability and usability of chemicals. An example is the proposed restriction of various triazoles, PFAS and MCCP, but also the classification of boric acid aside of combining REACH with consumer and worker protection measures. The ever-expanding legislation leads to complex rules under which chemicals can be approved and used in lubricants, requiring the Committee to adapt to this environment.
To reflect on the aforementioned challenges, the Committee is working on the reorganisation of its structure in order to facilitate its efficient functioning. For this reorganisation, the key development will be the establishment of working groups that focus on specific topics such as changes under REACH and CLP between the HSE meetings. In addition, “folder champions” will provide updates on selected, narrowly defined topics in the three committee meetings organised throughout the year.
Regarding the dynamic regulatory framework, a foretaste can be seen in the planned or active restrictions on biocides, fluorinated hydrocarbons and chlorinated paraffins. Here, the HSE Committee is also working with other associations to gather and communicate arguments to the authorities. Together with ATIEL and ATC we participated in consultations on the use of PFAS, and established communication papers on the proposed classification on Li-salts, the key constituent of many greases. We are also in direct contact with the EU and had another conference call with DG Environment in October. Moreover, a meeting with SMEunited took place to explore how we can coordinate our interests. The next year will be crucial for the Committee in getting its voice through on issues directly affecting our industry.