Challenges Encountered During The Initial Stages Of Exposure Assessment In REACH Registrations
Two decades have gone by since the implementation of the EU REACH regulation, and registrants are still facing numerous challenges at every step of exposure assessment, such as collection of key input parameters, description of the lifecycle tree, definition of a strategy, and/or exposure estimation itself.
A scientifically sound rationale is required for the selection of the key input parameters affecting the human health and environmental exposure assessment, including physico-chemical (PC) and environmental fate (Efate) properties, an especially daunting task in the case of complex substances such as UVCBs.
ECHA Guidance Chapter R.12 on building life cycle trees must be understood and followed. Organized and logic lists of uses are key to ease the communication down the supply chain, and some watchouts on tonnage and spERCs selection should be considered to avoid over-estimation of exposure.