WEBVTT 1 00:00:00.316 --> 00:00:02.016 Safer Chemicals Podcast. 2 00:00:02.736 --> 00:00:04.855 Sound science on harmful chemicals. 3 00:00:10.820 --> 00:00:13.039 Welcome to the Safer Chemicals Podcast. 4 00:00:13.617 --> 00:00:14.539 In this episode, 5 00:00:14.797 --> 00:00:20.406 we will deconstruct the meetings of the Risk Assessment and Socio-Economic Analysis Committees' December meetings. 6 00:00:21.265 --> 00:00:21.765 This time, 7 00:00:21.937 --> 00:00:23.375 we're doing things a little bit differently. 8 00:00:23.968 --> 00:00:26.156 So you might remember that at the end of our last episode, 9 00:00:26.406 --> 00:00:27.109 we invited you, 10 00:00:27.297 --> 00:00:27.922 our listeners, 11 00:00:28.084 --> 00:00:29.946 to send in questions on PFAS. 12 00:00:30.687 --> 00:00:32.490 Thank you very much to everyone who contributed. 13 00:00:32.669 --> 00:00:35.310 We'll be tackling those questions during the PFAS segment, 14 00:00:35.591 --> 00:00:36.634 so stay tuned for that. 15 00:00:37.814 --> 00:00:39.877 We'll keep doing this also for upcoming episodes, 16 00:00:40.017 --> 00:00:43.002 so if you do have specific questions for Roberto and Maria, 17 00:00:43.283 --> 00:00:46.580 or if you have suggestions for topics you would like us to cover in the podcast, 18 00:00:46.798 --> 00:00:50.298 send them to us at video@echa.europa.eu. 19 00:00:51.892 --> 00:00:54.783 Today we'll be covering two major topics from the December meetings. 20 00:00:55.096 --> 00:00:58.520 The first is the ongoing work on the universal PFAS restriction proposal, 21 00:00:58.620 --> 00:01:01.544 something that's been recurring since this restriction proposal came to us, 22 00:01:02.122 --> 00:01:05.427 including which sectors were discussed and what's coming up next. 23 00:01:06.270 --> 00:01:09.130 We'll also talk about a new milestone for the Risk Assessment Committee. 24 00:01:09.450 --> 00:01:15.380 And this was the first classification opinion using new hazard classes from the CLP regulation, 25 00:01:15.911 --> 00:01:22.677 focusing on a substance identified as very persistent and very bioaccumulative or VPVB. 26 00:01:23.645 --> 00:01:24.520 Roberto Maria. 27 00:01:24.788 --> 00:01:26.110 Thank you both for joining us again. 28 00:01:26.770 --> 00:01:27.129 Thank you. 29 00:01:27.211 --> 00:01:27.491 Thank you, 30 00:01:27.510 --> 00:01:27.670 Adam. 31 00:01:27.692 --> 00:01:28.692 It's a pleasure to be back. 32 00:01:28.833 --> 00:01:29.872 Last time in 25, 33 00:01:29.915 --> 00:01:30.094 right, 34 00:01:30.153 --> 00:01:30.333 Maria? 35 00:01:30.334 --> 00:01:31.094 Last time in 25, 36 00:01:31.133 --> 00:01:31.313 yes, 37 00:01:31.395 --> 00:01:31.633 indeed. 38 00:01:31.657 --> 00:01:32.133 A pleasure, 39 00:01:32.134 --> 00:01:32.317 Adam. 40 00:01:32.575 --> 00:01:32.758 Yes, 41 00:01:32.813 --> 00:01:33.040 indeed. 42 00:01:33.055 --> 00:01:34.399 This is our last episode of the year. 43 00:01:35.040 --> 00:01:35.360 But okay, 44 00:01:35.438 --> 00:01:37.704 let's start with the universal PFAS restriction proposal. 45 00:01:37.797 --> 00:01:37.922 So, 46 00:01:38.399 --> 00:01:38.899 Roberto, 47 00:01:39.141 --> 00:01:43.219 could you give us an overview of the discussions in the committee during this round of meetings? 48 00:01:43.688 --> 00:01:46.922 And why did you find the PFAS manufacturing discussion so interesting? 49 00:01:48.688 --> 00:01:48.954 Indeed, 50 00:01:48.955 --> 00:01:52.954 the discussion was focused on the PFAS manufacturing and horizontal issues, 51 00:01:53.001 --> 00:01:54.032 so we had those 52 00:01:54.284 --> 00:01:55.546 big sectors and 53 00:01:56.065 --> 00:01:58.688 PFAS manufacturing was indeed a special discussion to me. 54 00:01:58.970 --> 00:01:59.407 Why so? 55 00:02:00.009 --> 00:02:00.188 Well, 56 00:02:00.368 --> 00:02:00.911 first of all, 57 00:02:01.032 --> 00:02:07.259 it is about the production of PFAS chemicals and not much they're use in a specific sector as we did so far. 58 00:02:08.118 --> 00:02:08.579 In addition, 59 00:02:08.595 --> 00:02:11.282 I think it's a bit at the origin of everything. 60 00:02:11.345 --> 00:02:11.923 And I found, 61 00:02:11.938 --> 00:02:17.579 if I can say it's somewhat amusing that it came to RAC toward the end of it and not at the start of it. 62 00:02:18.063 --> 00:02:18.563 And why so? 63 00:02:18.735 --> 00:02:20.829 Because there were a number of 64 00:02:20.968 --> 00:02:24.088 pollution cases in some European manufacturing sites, 65 00:02:24.129 --> 00:02:25.569 in some European countries. 66 00:02:25.768 --> 00:02:27.588 I can remember something like Italy, 67 00:02:28.209 --> 00:02:28.549 Belgium, 68 00:02:28.550 --> 00:02:29.326 or the Netherlands. 69 00:02:29.389 --> 00:02:31.451 And this caused contamination of soil, 70 00:02:31.928 --> 00:02:32.272 water, 71 00:02:32.334 --> 00:02:33.014 groundwater. 72 00:02:33.592 --> 00:02:35.514 And so local governments, 73 00:02:35.530 --> 00:02:36.287 they took action. 74 00:02:36.530 --> 00:02:40.272 And probably this was also the result of the submission of the restriction itself. 75 00:02:40.287 --> 00:02:42.319 And this is what we are discussing here today. 76 00:02:43.006 --> 00:02:49.553 We also learned that experiences in remediation can be very costly when they can apply at all. 77 00:02:51.237 --> 00:02:51.397 Also, 78 00:02:51.477 --> 00:03:00.203 maybe to say that manufacturing affects all other sectors because it is about the production of PFAS that then it's used to make something else. 79 00:03:00.204 --> 00:03:03.211 I think we discussed this in other sectors such as cosmetics, 80 00:03:04.188 --> 00:03:05.649 medical devices and others. 81 00:03:07.211 --> 00:03:07.336 Well, 82 00:03:07.399 --> 00:03:07.680 actually, 83 00:03:08.180 --> 00:03:09.211 going back to what you said there, 84 00:03:09.477 --> 00:03:10.180 something you mentioned, 85 00:03:10.181 --> 00:03:13.383 you said that this local action was somehow tied to this restriction proposal. 86 00:03:13.399 --> 00:03:14.274 Can you just clarify how? 87 00:03:14.742 --> 00:03:15.258 Why is that? 88 00:03:15.688 --> 00:03:15.888 Well, 89 00:03:15.908 --> 00:03:23.150 we have learned from a number of documents that have been shared by the dossier submitters that in some specific instances, 90 00:03:23.509 --> 00:03:24.173 local authorities, 91 00:03:24.174 --> 00:03:24.931 they took action, 92 00:03:25.009 --> 00:03:31.657 they implemented more restrictive emission factors for the companies that are acting there. 93 00:03:31.954 --> 00:03:32.532 In some cases, 94 00:03:32.548 --> 00:03:35.345 there are even court cases that are ongoing. 95 00:03:35.829 --> 00:03:41.298 So it's definitely something that caught the attention of local authorities and even public media, 96 00:03:41.299 --> 00:03:41.673 I would say. 97 00:03:42.017 --> 00:03:42.236 Okay. 98 00:03:42.456 --> 00:03:42.636 Okay. 99 00:03:42.716 --> 00:03:42.857 Well, 100 00:03:42.897 --> 00:03:43.257 I mean, 101 00:03:43.277 --> 00:03:45.098 I see now why the sector caught your attention. 102 00:03:45.158 --> 00:03:47.461 And what about then the content of the discussion? 103 00:03:47.582 --> 00:03:50.820 So is there something else that kind of puts aside this sector? 104 00:03:52.945 --> 00:03:53.125 Well, 105 00:03:53.266 --> 00:03:53.805 as usual, 106 00:03:53.945 --> 00:03:57.469 we must take into account what are the volumes, 107 00:03:57.711 --> 00:03:59.367 try to estimate the emissions, 108 00:03:59.445 --> 00:04:03.070 but also having a view from the risk reduction perspective, 109 00:04:03.133 --> 00:04:05.274 whether some options are better than others. 110 00:04:05.961 --> 00:04:11.899 What was special was that the five authorities proposed a possible maximum emission limit. 111 00:04:12.749 --> 00:04:15.431 to the emissions for PFAS manufacturers. 112 00:04:15.511 --> 00:04:19.073 This was based on a voluntary initiative that was proposed by industry. 113 00:04:20.616 --> 00:04:20.976 However, 114 00:04:20.999 --> 00:04:22.195 on the emission factors, 115 00:04:22.359 --> 00:04:27.062 RAC supported rather the applicability of the Industrial Emission Directive, 116 00:04:27.085 --> 00:04:29.702 that is an existing legal framework at local level. 117 00:04:30.202 --> 00:04:35.734 This would be able to establish actually a site-specific limit value rather than a generic one. 118 00:04:36.296 --> 00:04:38.030 We also benefited from the input of 119 00:04:38.515 --> 00:04:41.562 European Commission experts from the Industrial Emission Directive. 120 00:04:42.157 --> 00:04:42.942 We also discussed, 121 00:04:43.103 --> 00:04:43.486 by the way, 122 00:04:43.487 --> 00:04:45.580 the limitations of this directive. 123 00:04:46.083 --> 00:04:46.763 Unfortunately, 124 00:04:46.963 --> 00:04:50.082 there are not yet specific best available techniques. 125 00:04:50.223 --> 00:04:52.606 They are called BATs in the sector for PFAS, 126 00:04:53.086 --> 00:04:55.086 and it could take several years to get them. 127 00:04:55.945 --> 00:05:02.328 We also discussed the possibility to implement risk management measures to actually improve the current situation, 128 00:05:03.094 --> 00:05:04.594 reducing total emissions. 129 00:05:05.109 --> 00:05:05.625 And finally, 130 00:05:05.688 --> 00:05:07.500 a lot of stakeholders attended again, 131 00:05:07.563 --> 00:05:10.500 and they commented a lot during the various presentations. 132 00:05:10.547 --> 00:05:11.391 So overall, 133 00:05:11.392 --> 00:05:13.406 a good discussion and good progress achieved. 134 00:05:14.411 --> 00:05:14.611 Okay, 135 00:05:14.691 --> 00:05:15.292 glad to hear that. 136 00:05:15.512 --> 00:05:20.297 And I understand that the Socio-Economic Analysis Committee also talked about the manufacturing sector, 137 00:05:20.337 --> 00:05:20.516 right? 138 00:05:21.540 --> 00:05:21.676 Yeah, 139 00:05:21.719 --> 00:05:22.219 that's correct. 140 00:05:22.258 --> 00:05:22.477 I mean, 141 00:05:22.540 --> 00:05:23.899 in the last plenary, 142 00:05:24.001 --> 00:05:30.188 we had had an initial discussion just presenting the proposal by the dossier submitter and initial impressions, 143 00:05:30.227 --> 00:05:33.313 but now we discussed it properly and we actually concluded as well. 144 00:05:33.766 --> 00:05:35.594 So quite a lot of good progress as well. 145 00:05:36.469 --> 00:05:42.360 so this one is one that is also a little bit atypical for us normally we spend quite a lot of time on a 146 00:05:42.447 --> 00:05:45.613 I've explained several times when talking about other sectors. 147 00:05:45.933 --> 00:05:48.138 We do a lot of work on the analysis of alternatives. 148 00:05:48.139 --> 00:05:53.884 So you look at sub-use by sub-use and see other alternatives for the use of PFAS here or not. 149 00:05:54.931 --> 00:05:57.712 But in PFAS manufacturing, 150 00:05:58.033 --> 00:05:58.509 mostly, 151 00:05:58.572 --> 00:05:59.243 for the most part, 152 00:05:59.290 --> 00:06:01.165 PFAS has no function per se. 153 00:06:03.023 --> 00:06:07.606 An analysis of alternatives is just not relevant because it's been produced to be used in other sectors. 154 00:06:07.688 --> 00:06:09.891 And those are the other sectors that we were assessing. 155 00:06:09.950 --> 00:06:10.130 So, 156 00:06:10.809 --> 00:06:11.048 you know, 157 00:06:11.094 --> 00:06:14.173 this analysis of alternatives wasn't so much of a thing here. 158 00:06:14.813 --> 00:06:16.173 There's one small exception, 159 00:06:16.259 --> 00:06:18.540 which is the use of PFAS as polymerisation aids. 160 00:06:18.594 --> 00:06:22.079 There you can do more of a traditional analysis of alternative. 161 00:06:22.094 --> 00:06:22.907 And we did that, 162 00:06:22.908 --> 00:06:23.344 of course. 163 00:06:23.626 --> 00:06:24.579 But for the most part, 164 00:06:24.969 --> 00:06:27.673 we were looking at the other aspects that we normally look at. 165 00:06:27.674 --> 00:06:28.641 We looked at the cost, 166 00:06:28.673 --> 00:06:29.141 of course, 167 00:06:29.173 --> 00:06:29.985 the benefits, 168 00:06:30.032 --> 00:06:31.969 the proportionality and derogations. 169 00:06:32.439 --> 00:06:33.560 And for this topic, 170 00:06:33.561 --> 00:06:38.084 we also considered the potential for emission minimization as part of the proportionality assessment. 171 00:06:38.103 --> 00:06:42.228 That was also a little bit different than in other sectors. 172 00:06:43.431 --> 00:06:47.431 Roberto was talking about this coming at the end and this being a little bit funny. 173 00:06:47.752 --> 00:06:50.095 I guess in a way it makes sense because at the end, 174 00:06:50.439 --> 00:06:55.783 we kind of we have a better view as to where we think that derogations will actually be needed. 175 00:06:55.814 --> 00:07:00.767 So what will we need PFAS for if the restriction comes in? 176 00:07:01.163 --> 00:07:06.103 So you get a little bit of a better picture as to what could happen if under the first restriction option, 177 00:07:06.325 --> 00:07:07.364 if everything is banned, 178 00:07:07.403 --> 00:07:08.005 for instance. 179 00:07:08.146 --> 00:07:08.306 Right. 180 00:07:08.423 --> 00:07:09.368 So to me, 181 00:07:09.407 --> 00:07:11.165 it made sense to have it this way. 182 00:07:11.446 --> 00:07:12.087 Looks better now. 183 00:07:12.642 --> 00:07:12.806 Okay, 184 00:07:12.868 --> 00:07:13.064 great. 185 00:07:13.087 --> 00:07:16.329 So then both committees discussed and concluded also on horizontal issues, 186 00:07:16.384 --> 00:07:16.626 right? 187 00:07:16.946 --> 00:07:19.649 And could you tell us kind of why this is so central, 188 00:07:19.728 --> 00:07:21.728 these horizontal issues to this restriction proposal? 189 00:07:22.743 --> 00:07:22.962 Yeah, 190 00:07:23.071 --> 00:07:27.431 what we call a horizontal issue is really at the heart of what we are doing in this restriction. 191 00:07:27.509 --> 00:07:29.524 And they are about cross-cutting. 192 00:07:29.751 --> 00:07:31.652 issues that are not sector specific, 193 00:07:31.693 --> 00:07:35.615 but they apply to the oil restriction as a single entity. 194 00:07:36.299 --> 00:07:37.498 And when it goes to RAC, 195 00:07:37.638 --> 00:07:42.904 this is about establishing the chemical identity of the PFAS that are actually subject to the restriction, 196 00:07:43.224 --> 00:07:44.388 what are the hazards, 197 00:07:44.467 --> 00:07:45.467 the potential risks, 198 00:07:46.474 --> 00:07:48.115 and why they must be controlled, 199 00:07:48.116 --> 00:07:52.427 but also the concentration limits above which PFAS will have to be restricted. 200 00:07:53.015 --> 00:07:59.921 And also recycling related aspects and general risk management measures to monitor and to reduce environmental emissions. 201 00:08:00.101 --> 00:08:00.961 Across all the sectors. 202 00:08:01.000 --> 00:08:01.265 Yes, 203 00:08:01.320 --> 00:08:01.484 yes, 204 00:08:01.546 --> 00:08:01.820 indeed. 205 00:08:02.742 --> 00:08:04.250 We've also got things like practicality, 206 00:08:04.328 --> 00:08:04.984 for instance, 207 00:08:05.046 --> 00:08:06.945 including enforceability as well. 208 00:08:07.007 --> 00:08:07.125 So, 209 00:08:07.148 --> 00:08:07.429 you know, 210 00:08:08.132 --> 00:08:09.625 can it actually be applied, 211 00:08:09.953 --> 00:08:10.593 the restriction? 212 00:08:11.250 --> 00:08:12.109 Can it be enforced? 213 00:08:12.140 --> 00:08:14.171 Can you monitor the progress made? 214 00:08:14.218 --> 00:08:16.640 So those are topics that we both look at, 215 00:08:16.718 --> 00:08:17.062 actually. 216 00:08:17.656 --> 00:08:20.421 And then there are other aspects that are more related only to SEAC. 217 00:08:20.559 --> 00:08:21.259 For instance, 218 00:08:21.819 --> 00:08:24.180 overarching impacts on trade and competitiveness, 219 00:08:24.279 --> 00:08:25.180 cumulative impacts, 220 00:08:25.219 --> 00:08:27.520 all those things we also looked at ourselves. 221 00:08:27.699 --> 00:08:27.898 Okay, 222 00:08:27.922 --> 00:08:30.723 so really a holistic picture overall of the impact of this. 223 00:08:30.801 --> 00:08:30.980 Good. 224 00:08:32.199 --> 00:08:36.824 What were then the highlights from the Risk Assessment Committee on these horizontal issues particularly? 225 00:08:37.762 --> 00:08:37.918 Well, 226 00:08:37.980 --> 00:08:38.246 first, 227 00:08:38.402 --> 00:08:40.887 this was not actually the first time we discussed the topic. 228 00:08:40.918 --> 00:08:43.184 It came already to the committee a number of times. 229 00:08:43.449 --> 00:08:47.043 So already many things were concluded in previous meetings. 230 00:08:47.683 --> 00:08:53.445 What we discussed this time and agree was about the general approach to estimate emissions in the virus life cycles, 231 00:08:54.445 --> 00:08:57.602 special focus on fluoropolymers and on the waste stage. 232 00:08:58.102 --> 00:08:59.906 But also we updated the effectiveness, 233 00:08:59.907 --> 00:09:04.531 the practicality and also the additional regulatory risk management options. 234 00:09:05.469 --> 00:09:10.328 The highlight for me was also the discussion on the site specific PFAS management plans. 235 00:09:10.875 --> 00:09:14.109 So this is something that RAC proposed to apply to all companies. 236 00:09:14.395 --> 00:09:18.877 possibly benefiting from derogations that could be granted by the institutions. 237 00:09:19.959 --> 00:09:29.049 The dossier submitter proposed those plans for some uses to incentivize substitution with other materials that have different properties than the PFAS one. 238 00:09:29.533 --> 00:09:29.869 However, 239 00:09:29.947 --> 00:09:33.127 RAC wanted to put more the emphasis on reducing emissions. 240 00:09:33.893 --> 00:09:42.643 So the plans should contain risk management measures to reduce those emissions such as preventing leaks or reducing emissions whenever possible. 241 00:09:43.083 --> 00:09:45.985 monitoring them because we need to know what actually happens, 242 00:09:46.247 --> 00:09:51.571 but also to communicate and inform across the supply chain because if you don't get the information you cannot act actually, 243 00:09:51.634 --> 00:09:53.634 that's a quite important element. 244 00:09:54.298 --> 00:10:00.938 There was also a focus on emissions related to the circular economy activities such as recycling, 245 00:10:01.048 --> 00:10:01.719 reuse, 246 00:10:01.720 --> 00:10:03.079 the use of spare parts, 247 00:10:03.548 --> 00:10:06.626 and also from potential derogations related to this sector. 248 00:10:07.141 --> 00:10:08.501 And finally some sectors were 249 00:10:08.647 --> 00:10:13.587 proposed to be excluded from the restriction and we looked at what this would mean for the restriction itself. 250 00:10:15.442 --> 00:10:15.982 All right. 251 00:10:16.002 --> 00:10:16.182 Thanks, 252 00:10:16.242 --> 00:10:16.562 Roberta. 253 00:10:16.743 --> 00:10:17.123 And for you, 254 00:10:17.164 --> 00:10:17.363 Maria? 255 00:10:18.125 --> 00:10:18.265 Well, 256 00:10:18.285 --> 00:10:20.707 we have discussed this topic in the past as well, 257 00:10:20.789 --> 00:10:21.609 quite a few times. 258 00:10:21.929 --> 00:10:26.429 It was one of the first ones we discussed when we started several years back already. 259 00:10:27.414 --> 00:10:29.734 And we kept bringing it back periodically. 260 00:10:29.836 --> 00:10:31.062 So in the past, 261 00:10:31.140 --> 00:10:32.640 and especially in the last plenary, 262 00:10:32.641 --> 00:10:36.984 we have discussed more topics like what do we think of the dossier submittance approach? 263 00:10:37.047 --> 00:10:38.047 How will we assess it? 264 00:10:39.000 --> 00:10:41.172 But we didn't go much into that this time. 265 00:10:41.312 --> 00:10:42.750 That's already closed down. 266 00:10:43.221 --> 00:10:45.424 So here we looked at more general topics. 267 00:10:45.504 --> 00:10:49.867 I mentioned some earlier and some of the ones that Roberto also talked about, 268 00:10:49.926 --> 00:10:51.027 like recycling, 269 00:10:52.012 --> 00:10:53.371 secondhand articles, 270 00:10:53.433 --> 00:10:54.230 spare parts. 271 00:10:54.652 --> 00:10:58.676 So there we had quite a lot of discussion and quite a lot of information. 272 00:10:58.754 --> 00:10:58.879 So, 273 00:10:59.097 --> 00:10:59.715 for instance, 274 00:11:00.090 --> 00:11:00.902 for recycling, 275 00:11:00.918 --> 00:11:04.418 we went into quite a lot of detail looking at recycling of plastics, 276 00:11:04.449 --> 00:11:05.402 of paper and board, 277 00:11:05.418 --> 00:11:06.090 of textiles, 278 00:11:06.121 --> 00:11:06.777 of metals. 279 00:11:07.199 --> 00:11:10.168 Conclusions are a little bit different for each of them. 280 00:11:10.693 --> 00:11:12.694 So we spent quite a lot of time doing that. 281 00:11:12.714 --> 00:11:20.444 So these are topics that were introduced in the dossier in the last update that the dossier submitted. 282 00:11:20.460 --> 00:11:23.226 So this is the first opportunity we have had to assess those. 283 00:11:24.124 --> 00:11:30.905 And I understood that the Socioeconomic Analysis Committee also finalized its conclusions on electronics and semiconductors, 284 00:11:30.968 --> 00:11:31.234 right? 285 00:11:31.593 --> 00:11:33.140 As kind of the last sector to be announced. 286 00:11:33.141 --> 00:11:33.452 Yes, 287 00:11:33.515 --> 00:11:33.999 exactly. 288 00:11:34.062 --> 00:11:34.359 That's a... 289 00:11:34.457 --> 00:11:35.698 bit of a beast of a sector. 290 00:11:35.759 --> 00:11:38.161 It's the biggest one in terms of received comments. 291 00:11:38.181 --> 00:11:38.761 And it's very, 292 00:11:38.823 --> 00:11:39.382 very complex. 293 00:11:39.401 --> 00:11:39.741 I mean, 294 00:11:40.081 --> 00:11:40.522 first of all, 295 00:11:40.523 --> 00:11:46.667 it's got two separate kind of sub sectors of electronics and semiconductors. 296 00:11:46.706 --> 00:11:48.534 And then when you go within that, 297 00:11:49.268 --> 00:11:50.175 there's even much, 298 00:11:50.292 --> 00:11:50.448 much, 299 00:11:50.495 --> 00:11:51.214 much more detail. 300 00:11:51.339 --> 00:11:52.839 So in the last plenary, 301 00:11:52.870 --> 00:11:55.042 we had discussed for semiconductors, 302 00:11:55.136 --> 00:11:57.792 the analysis of alternatives and the costs. 303 00:11:58.339 --> 00:11:59.761 So now this time we have brought 304 00:11:59.849 --> 00:12:06.750 that all together and also done the same for electronics and looked at the whole electronics and semiconductors as a whole. 305 00:12:06.809 --> 00:12:09.153 So there is quite a lot there. 306 00:12:09.848 --> 00:12:13.215 And it's a very technical sector as well, 307 00:12:13.254 --> 00:12:13.629 let's say. 308 00:12:13.731 --> 00:12:18.637 So that was quite a lot of work done by the teams to get to grips with things, 309 00:12:18.638 --> 00:12:25.137 to understand really how different things work within it and to understand the applications. 310 00:12:25.340 --> 00:12:26.137 And yeah, 311 00:12:26.138 --> 00:12:28.200 I think that was quite a long discussion as well. 312 00:12:28.277 --> 00:12:28.938 And I suppose there, 313 00:12:28.939 --> 00:12:34.444 the kind of the stakeholder expertise that you get in the committees also supports this kind of knowledge sharing and understanding work. 314 00:12:34.483 --> 00:12:34.784 Yes, 315 00:12:34.785 --> 00:12:35.144 it helps. 316 00:12:35.163 --> 00:12:39.210 We had some very helpful interventions from stakeholders explaining things. 317 00:12:39.288 --> 00:12:40.608 And also, 318 00:12:40.648 --> 00:12:41.046 of course, 319 00:12:41.069 --> 00:12:43.491 the information submitted is crucial there. 320 00:12:43.694 --> 00:12:43.812 So, 321 00:12:44.054 --> 00:12:44.288 you know, 322 00:12:44.913 --> 00:12:47.319 that really allows to do the assessment properly. 323 00:12:48.335 --> 00:12:48.616 Okay, 324 00:12:48.694 --> 00:12:49.101 good to hear. 325 00:12:49.179 --> 00:12:49.319 Well, 326 00:12:49.757 --> 00:12:50.382 with this then, 327 00:12:50.491 --> 00:12:55.819 both committees have concluded their discussions on the 14 sectors and PFAS manufacturing. 328 00:12:56.382 --> 00:12:57.148 What happens next? 329 00:12:57.889 --> 00:12:58.029 Well, 330 00:12:58.049 --> 00:13:01.031 I think this is amazing and I think it's a great achievement. 331 00:13:01.453 --> 00:13:01.973 Now for RAC, 332 00:13:01.992 --> 00:13:03.613 we have the last mile to be concluded, 333 00:13:03.633 --> 00:13:03.894 but I'm... 334 00:13:04.457 --> 00:13:05.758 They see the light at the end of the tunnel. 335 00:13:05.759 --> 00:13:06.578 We don't quite. 336 00:13:06.656 --> 00:13:07.195 Not yet. 337 00:13:07.742 --> 00:13:09.539 I think it's not yet time to celebrate. 338 00:13:09.578 --> 00:13:18.164 I'm sure Maria will join me in spending a few words of appreciation for the amazing work that reporters and the ECAS secretary have put into it at the end of the day. 339 00:13:18.914 --> 00:13:21.680 This is about real people and non-artificial intelligence. 340 00:13:21.681 --> 00:13:23.367 So this is the hard work of human. 341 00:13:23.711 --> 00:13:24.711 So let's acknowledge this. 342 00:13:24.758 --> 00:13:25.898 I think it's nice. 343 00:13:26.713 --> 00:13:27.434 And on RAC's side, 344 00:13:27.474 --> 00:13:37.059 now we will have to carefully draft the final opinion text and ensure that all cross-horizontal issues are reflected in the same manner across all various sectors. 345 00:13:37.122 --> 00:13:40.989 So we need 14 sectors and PFAS manufacturing to be put together. 346 00:13:41.606 --> 00:13:42.004 Our goal, 347 00:13:42.028 --> 00:13:42.411 as usual, 348 00:13:42.450 --> 00:13:47.340 is to have a scientifically sound and consistent opinion ready for March 2026, 349 00:13:47.575 --> 00:13:49.512 when RAC will adopt its opinion. 350 00:13:50.075 --> 00:13:50.981 And on the CX side, 351 00:13:50.997 --> 00:13:51.762 it's very similar. 352 00:13:51.840 --> 00:13:51.965 we 353 00:13:52.297 --> 00:13:53.217 put everything together? 354 00:13:53.237 --> 00:13:53.377 Well, 355 00:13:53.398 --> 00:13:53.858 first of all, 356 00:13:53.859 --> 00:13:54.618 we have to go back, 357 00:13:54.677 --> 00:13:57.519 make sure that everything is consistent across all the sectors. 358 00:13:57.960 --> 00:13:58.917 It's been a long time. 359 00:13:59.019 --> 00:13:59.898 Things have changed. 360 00:13:59.980 --> 00:14:00.499 Sometimes, 361 00:14:00.538 --> 00:14:00.796 you know, 362 00:14:00.882 --> 00:14:03.616 things are not completely consistent with each other. 363 00:14:03.679 --> 00:14:04.757 So we'll do that. 364 00:14:05.241 --> 00:14:07.062 And then we'll put everything together as the, 365 00:14:07.218 --> 00:14:07.460 you know, 366 00:14:07.483 --> 00:14:08.741 the general opinion. 367 00:14:09.241 --> 00:14:09.554 And that, 368 00:14:09.585 --> 00:14:09.819 again, 369 00:14:09.835 --> 00:14:11.023 is coming for, 370 00:14:11.444 --> 00:14:11.960 in circuits, 371 00:14:12.023 --> 00:14:13.601 for agreement in March. 372 00:14:14.023 --> 00:14:17.023 So what's the difference between agreement and adoption? 373 00:14:17.545 --> 00:14:19.747 All it means is that it's not final yet. 374 00:14:19.808 --> 00:14:23.409 So we agree it and then we open the consultation. 375 00:14:23.569 --> 00:14:25.394 So after the March meeting, 376 00:14:25.413 --> 00:14:25.972 we launch a 377 00:14:26.417 --> 00:14:28.737 60-day consultation on this draft opinion. 378 00:14:29.339 --> 00:14:32.737 So it doesn't get adopted until after that, 379 00:14:32.839 --> 00:14:33.339 basically. 380 00:14:33.956 --> 00:14:34.081 So, 381 00:14:34.534 --> 00:14:34.659 yeah, 382 00:14:34.706 --> 00:14:36.206 this is how it's built in the regulation. 383 00:14:36.222 --> 00:14:39.862 We have an additional consultation while RAC adopts a little bit earlier. 384 00:14:41.217 --> 00:14:44.621 It helps because we then get a stable rack opinion to work with, 385 00:14:44.720 --> 00:14:51.343 because of course there's quite a lot of interactions in between and most of them are going more in the rack towards SEAC direction than the opposite. 386 00:14:52.439 --> 00:14:52.619 Okay, 387 00:14:52.659 --> 00:14:52.779 well, 388 00:14:52.780 --> 00:14:53.379 so for RAC, 389 00:14:53.580 --> 00:14:53.740 well, 390 00:14:53.840 --> 00:14:54.682 Risk Assessment Committee, 391 00:14:54.683 --> 00:14:58.783 the finishing line is on the horizon for the Socioeconomic Analysis Committee. 392 00:14:59.287 --> 00:15:01.068 Let's talk about that consultation a little bit. 393 00:15:01.108 --> 00:15:04.873 So kind of what should stakeholders expect and how can they best contribute? 394 00:15:05.490 --> 00:15:05.670 Well, 395 00:15:05.748 --> 00:15:12.303 just maybe first thing to mention is we announced in the last podcast that we were going to do a webinar and that now has happened. 396 00:15:12.443 --> 00:15:15.381 It happened in October and that can be found on our website. 397 00:15:15.382 --> 00:15:17.225 There's quite a lot of information there. 398 00:15:17.815 --> 00:15:24.640 So what we're basically asking the stakeholders to do is to start preparing already for the consultation. 399 00:15:25.241 --> 00:15:27.601 There is also going to be a mapping of PFAS uses. 400 00:15:28.187 --> 00:15:28.304 Well, 401 00:15:28.546 --> 00:15:33.804 one is already available and we continue to work on that and many further support materials will follow as well. 402 00:15:34.257 --> 00:15:39.835 So the idea is that we would like people to engage really early and start preparing what they will submit. 403 00:15:39.882 --> 00:15:43.179 It is a short consultation and that is, 404 00:15:43.180 --> 00:15:43.476 I think, 405 00:15:43.585 --> 00:15:46.710 going to be one of the big challenges that are coming. 406 00:15:47.067 --> 00:15:47.187 Well, 407 00:15:47.188 --> 00:15:49.008 actually going to challenges and opportunities, 408 00:15:49.389 --> 00:15:52.573 what do you foresee in terms of those in the consultation process? 409 00:15:52.772 --> 00:15:52.913 Well, 410 00:15:53.053 --> 00:15:55.491 with consultations on the SEAC draft opinion, 411 00:15:56.092 --> 00:15:57.499 the big challenge is always the same. 412 00:15:57.538 --> 00:15:58.999 It's matching our needs. 413 00:15:59.256 --> 00:16:02.225 What do we need to make this opinion the best possible? 414 00:16:02.881 --> 00:16:06.522 And the stakeholders decide to provide their information, 415 00:16:06.631 --> 00:16:08.163 just trying to make sure that those match, 416 00:16:08.272 --> 00:16:10.569 that the information provided is actually what we need. 417 00:16:10.803 --> 00:16:10.928 Yep. 418 00:16:11.335 --> 00:16:11.444 So. 419 00:16:12.403 --> 00:16:15.225 this consultation is about our SEAC draft opinion. 420 00:16:15.266 --> 00:16:17.348 It's not a general consultation on the topic. 421 00:16:17.508 --> 00:16:18.348 That's an important distinction. 422 00:16:18.349 --> 00:16:19.954 That's a very important distinction. 423 00:16:20.610 --> 00:16:28.423 And this is why we're spending so much effort providing guidance and designing the consultation so that it focuses on the areas where we really need more evidence. 424 00:16:28.891 --> 00:16:31.501 And we are able to communicate that to the stakeholders. 425 00:16:31.563 --> 00:16:32.829 We're telling them exactly, 426 00:16:33.344 --> 00:16:34.126 this is what we need. 427 00:16:34.626 --> 00:16:36.001 This is where we need information. 428 00:16:36.469 --> 00:16:38.126 And they can already start preparing it. 429 00:16:38.407 --> 00:16:38.532 So, 430 00:16:38.533 --> 00:16:38.735 I mean... 431 00:16:39.347 --> 00:16:40.368 When we talk about timing, 432 00:16:40.608 --> 00:16:41.649 that really is a challenge. 433 00:16:41.650 --> 00:16:42.911 It's a short consultation. 434 00:16:42.989 --> 00:16:44.071 It's 60 days. 435 00:16:44.130 --> 00:16:45.153 That's reached us. 436 00:16:45.872 --> 00:16:52.321 And the other thing as well is that the actual opinion only becomes available at the point when we open the consultation. 437 00:16:52.438 --> 00:16:55.423 So there is a limited amount of time to reach the end desk. 438 00:16:55.923 --> 00:16:56.282 Of course, 439 00:16:56.283 --> 00:16:59.391 the stakeholders who have been following the process through the committees, 440 00:16:59.907 --> 00:17:03.157 they have had access to the draft versions. 441 00:17:03.532 --> 00:17:04.595 Those may change a bit, 442 00:17:04.610 --> 00:17:05.079 of course, 443 00:17:05.516 --> 00:17:08.016 and many people won't have had access to that. 444 00:17:08.695 --> 00:17:10.296 So what we are going to, 445 00:17:10.717 --> 00:17:15.641 what we are doing at the moment is providing them the information about what information we'll be asking about, 446 00:17:16.063 --> 00:17:18.785 so that even without reading the opinion and seeing it, 447 00:17:18.786 --> 00:17:20.168 you can already start preparing. 448 00:17:20.169 --> 00:17:28.231 You can already start looking at all the data that you have and drawing out things at the right level and at the right level of granularity as well, 449 00:17:28.278 --> 00:17:31.403 which is where we need to be able to conclude properly. 450 00:17:32.059 --> 00:17:32.871 And yeah, 451 00:17:32.872 --> 00:17:35.434 I think that that's if people spend time. 452 00:17:35.839 --> 00:17:36.339 preparing, 453 00:17:36.379 --> 00:17:39.001 I think we can get something really good at the end of it. 454 00:17:40.044 --> 00:17:41.903 This bridges nicely to our audience questions. 455 00:17:41.986 --> 00:17:42.986 So we got two, 456 00:17:43.286 --> 00:17:46.232 and both were on the upcoming consultation. 457 00:17:46.310 --> 00:17:54.841 So the first one was about these eight sectors that the five authorities added to the proposal following the first consultation. 458 00:17:55.357 --> 00:17:56.544 This question has two parts. 459 00:17:56.575 --> 00:17:57.419 So first of all, 460 00:17:57.435 --> 00:18:00.419 I'd like to explain what the issue is with these eight sectors. 461 00:18:00.560 --> 00:18:01.810 And then the actual question is, 462 00:18:02.232 --> 00:18:05.544 how can stakeholders submit new information on these during the consultation? 463 00:18:06.411 --> 00:18:06.591 Okay, 464 00:18:06.651 --> 00:18:06.791 yeah. 465 00:18:06.871 --> 00:18:11.376 So the issue with these eight sectors is that although they are part of the proposal, 466 00:18:11.396 --> 00:18:11.896 they're covered, 467 00:18:12.657 --> 00:18:16.942 RAC and SEAC will not be doing a sector-specific evaluation of these sectors. 468 00:18:17.239 --> 00:18:25.036 So that is the reason why people are asking about how can they submit information about them and they want to understand how it will work. 469 00:18:25.849 --> 00:18:27.771 So it's important to be very clear. 470 00:18:28.005 --> 00:18:30.833 The SEAC draft opinion and the RAC draft opinion, 471 00:18:30.989 --> 00:18:33.599 they cover the full scope of the restriction proposal. 472 00:18:33.614 --> 00:18:34.724 So all PFAS. 473 00:18:35.051 --> 00:18:37.253 and all uses except for firefighting forms, 474 00:18:37.294 --> 00:18:38.554 which is covered elsewhere. 475 00:18:38.675 --> 00:18:38.874 Yes, 476 00:18:39.075 --> 00:18:39.395 indeed. 477 00:18:39.997 --> 00:18:46.118 So we're asking people to provide comments on any of the aspects of the CERC evaluation that they wish, 478 00:18:46.845 --> 00:18:49.727 including the eight additional sectors if they wish to do so. 479 00:18:49.743 --> 00:18:51.805 So they can submit the consultation. 480 00:18:52.212 --> 00:18:54.524 So the consultation has two parts, 481 00:18:54.587 --> 00:18:54.977 let's say. 482 00:18:55.165 --> 00:19:02.274 They have very specific questions on the sectors where we do this sector-specific evaluation. 483 00:19:02.352 --> 00:19:03.524 there we're asking about. 484 00:19:04.051 --> 00:19:05.191 analysis of alternatives, 485 00:19:05.250 --> 00:19:05.731 costs, 486 00:19:05.811 --> 00:19:06.392 benefits, 487 00:19:06.431 --> 00:19:07.210 proportionality, 488 00:19:07.511 --> 00:19:08.312 all those details. 489 00:19:09.370 --> 00:19:14.730 But there are also more general questions on all the different sections of the SEAC opinion. 490 00:19:15.175 --> 00:19:17.355 And this also includes analysis of alternatives, 491 00:19:17.394 --> 00:19:17.691 costs, 492 00:19:17.714 --> 00:19:18.214 benefits. 493 00:19:18.574 --> 00:19:24.870 So they are able to submit information about those eight sectors in those sections of the consultation. 494 00:19:24.871 --> 00:19:26.074 I think that's really important to know. 495 00:19:27.433 --> 00:19:28.480 So to summarize, 496 00:19:28.558 --> 00:19:32.870 the consultation is not just about the 14 sectors and PFAS manufacturing. 497 00:19:33.179 --> 00:19:35.320 It covers all aspects of the draft opinion, 498 00:19:35.400 --> 00:19:39.685 so anyone interested can share their thoughts on any part of the committee's evaluation. 499 00:19:40.346 --> 00:19:42.006 That includes things like alternatives, 500 00:19:42.107 --> 00:19:42.467 costs, 501 00:19:42.529 --> 00:19:42.990 benefits, 502 00:19:43.068 --> 00:19:43.685 as you mentioned, 503 00:19:43.686 --> 00:19:44.607 so the whole picture. 504 00:19:45.389 --> 00:19:51.670 Good to keep in mind that any relevant information you give will help the committee check or update its conclusions in the opinion. 505 00:19:52.139 --> 00:19:52.654 So basically, 506 00:19:52.810 --> 00:19:54.420 if you've got insights on the draft opinion, 507 00:19:54.717 --> 00:19:55.764 now's the time to speak up. 508 00:19:56.752 --> 00:20:01.997 The second question we received was on the decision to not allow attachments in the upcoming consultation. 509 00:20:02.036 --> 00:20:02.736 Very specific. 510 00:20:02.779 --> 00:20:07.165 So can you explain the thinking here and why is that potentially such a sensitive issue? 511 00:20:08.103 --> 00:20:08.282 Yeah, 512 00:20:08.423 --> 00:20:16.150 so the reason why we have structured the consultation in the way we have by using a survey approach is to, 513 00:20:16.556 --> 00:20:16.806 you know, 514 00:20:17.150 --> 00:20:23.118 resolve this challenge that I mentioned a little while back about making sure that what is provided actually matches what we need. 515 00:20:23.816 --> 00:20:30.363 So we want to make sure that people don't waste their time sending us things that won't be able to be used because they're not at the right level, 516 00:20:30.383 --> 00:20:31.363 they're not the right thing. 517 00:20:31.863 --> 00:20:37.832 So that's why we are providing the information this way and asking for the information this way rather. 518 00:20:38.332 --> 00:20:43.113 And we provide quite a lot of space to give us data, 519 00:20:44.113 --> 00:20:46.004 even if attachments are not allowed. 520 00:20:46.592 --> 00:20:49.715 There are multiple questions and they cover all aspects of the draft opinion. 521 00:20:49.775 --> 00:20:52.799 So there's quite a lot of space to provide information. 522 00:20:52.838 --> 00:20:53.100 There are, 523 00:20:53.101 --> 00:20:53.396 of course, 524 00:20:53.420 --> 00:20:54.139 character limits, 525 00:20:54.158 --> 00:20:55.381 but they are very generous, 526 00:20:55.420 --> 00:20:55.920 I must say. 527 00:20:56.561 --> 00:21:04.709 And collecting also the comments in a way that's more structured also allows us to process the information more effectively. 528 00:21:05.396 --> 00:21:09.896 And for the information that comes in to have a bigger impact on the opinion making process as well, 529 00:21:09.928 --> 00:21:12.553 which is the whole point of why we run the consultation. 530 00:21:12.912 --> 00:21:13.092 Right. 531 00:21:13.093 --> 00:21:14.954 And you've run a few consultations in the past. 532 00:21:14.955 --> 00:21:18.118 So I guess you've also understood from there that once these attachments start coming in, 533 00:21:18.196 --> 00:21:21.880 you do get a lot of things that may not be included at all because they're just not relevant. 534 00:21:21.919 --> 00:21:23.185 So it's also a left unlearned. 535 00:21:23.544 --> 00:21:23.685 Yeah, 536 00:21:23.700 --> 00:21:26.325 I think we have learned a lot from previous consultations, 537 00:21:26.388 --> 00:21:29.810 including the one on the Annex 15 dossier in this case. 538 00:21:30.388 --> 00:21:32.153 And all these lessons that we have learned, 539 00:21:32.154 --> 00:21:35.341 we have applied to try to make this consultation the best possible. 540 00:21:35.950 --> 00:21:36.638 All right. 541 00:21:36.639 --> 00:21:36.763 Well, 542 00:21:36.778 --> 00:21:37.075 thank you. 543 00:21:37.076 --> 00:21:38.856 I think that concludes the audience questions. 544 00:21:38.984 --> 00:21:39.264 part. 545 00:21:39.443 --> 00:21:40.204 And as you mentioned, 546 00:21:40.205 --> 00:21:43.166 we did organize a webinar on this in October, 547 00:21:43.205 --> 00:21:43.783 I think it was, 548 00:21:44.264 --> 00:21:47.084 and we'll be adding a link to that in this episode's description. 549 00:21:47.225 --> 00:21:48.326 So do check that out. 550 00:21:49.006 --> 00:21:52.350 But now let's conclude on PFAS for today. 551 00:21:52.443 --> 00:21:53.623 We'll come back to it next year. 552 00:21:54.123 --> 00:21:55.022 Long sigh of relief. 553 00:21:55.209 --> 00:21:55.428 Good. 554 00:21:56.412 --> 00:21:57.725 Let's move on to our second topic. 555 00:21:57.772 --> 00:22:05.865 So this was the first time classification opinion from the Risk Assessment Committee on new hazard classes under the CLP regulation. 556 00:22:06.428 --> 00:22:06.850 Roberto, 557 00:22:06.943 --> 00:22:07.568 can you explain? 558 00:22:07.936 --> 00:22:10.638 Why this is such a significant milestone to the committee? 559 00:22:11.718 --> 00:22:14.984 We should probably start from the revision of the CLP regulation, 560 00:22:15.043 --> 00:22:15.664 classification, 561 00:22:15.722 --> 00:22:21.085 labeling and packaging regulation in 23 that was modified introducing new hazard classes, 562 00:22:21.585 --> 00:22:23.328 both for environment and human health. 563 00:22:23.929 --> 00:22:25.757 And for some of them, 564 00:22:25.820 --> 00:22:29.382 we had some previous experience in other processes such as PBT, 565 00:22:30.070 --> 00:22:33.664 persistent bioaccumulative and toxic substances in SVHC, 566 00:22:33.898 --> 00:22:35.570 substances of very high concern, 567 00:22:35.664 --> 00:22:36.617 a lot of acronym, 568 00:22:36.679 --> 00:22:36.992 sorry. 569 00:22:39.249 --> 00:22:44.675 But what is new is indeed that those new hazard classes were not available earlier, 570 00:22:44.796 --> 00:22:46.077 and particularly PMT, 571 00:22:46.335 --> 00:22:48.421 so persistent mobility and toxicity, 572 00:22:48.999 --> 00:22:49.616 or for instance, 573 00:22:49.639 --> 00:22:52.561 endocrine-disrupting properties for human health or environment. 574 00:22:52.624 --> 00:22:53.530 And for the first time, 575 00:22:53.577 --> 00:22:55.171 RAC assessed a first case. 576 00:22:56.171 --> 00:22:57.749 I will not read the name of the substance, 577 00:22:57.780 --> 00:22:59.124 not to confuse our listeners, 578 00:22:59.233 --> 00:23:04.499 but the conclusion was that it was very persistent and very bioaccumulative into the environment. 579 00:23:05.108 --> 00:23:06.436 And this definitely sets a... 580 00:23:06.452 --> 00:23:26.353 precedent is the first time and more proposals to classify substances with the new hazard classes will come and this will include for instance endocrine disrupting properties in 26 and the committee as usual will face new challenges because those are new criteria we have guidance but guidance is often not everything 581 00:23:26.447 --> 00:23:35.697 we need to test the system with real data and this is what we have done but i think we are in a good position to to make this happen and to be to have a successful assessment also in 582 00:23:35.832 --> 00:23:37.893 26 for the upcoming new substances. 583 00:23:38.915 --> 00:23:39.116 Right. 584 00:23:39.456 --> 00:23:39.616 Well, 585 00:23:39.756 --> 00:23:43.760 could you briefly outline kind of the scientific basis for the very persistent, 586 00:23:43.862 --> 00:23:46.182 very bioaccumulative classification in this case? 587 00:23:47.104 --> 00:23:47.502 Indeed, 588 00:23:47.565 --> 00:23:47.784 well, 589 00:23:47.924 --> 00:23:53.588 we can start saying that in the specific cases about the property, 590 00:23:53.651 --> 00:23:56.979 the intrinsic property of a substance to persist into the environment, 591 00:23:56.995 --> 00:24:02.432 to stay without being naturally biodegraded in something else, 592 00:24:02.916 --> 00:24:04.823 in normal environmental conditions. 593 00:24:05.063 --> 00:24:06.943 and to accumulate in a living organism. 594 00:24:07.305 --> 00:24:11.307 So the possibility to basically build a stock in time in a specific organism. 595 00:24:11.725 --> 00:24:18.428 And this was considered as a relevant hazard that should be subject to classification and also to labeling to inform also potential users. 596 00:24:18.787 --> 00:24:19.248 To do so, 597 00:24:19.365 --> 00:24:21.709 we use what we call specific markers. 598 00:24:22.943 --> 00:24:23.475 For instance, 599 00:24:23.490 --> 00:24:26.490 if the substance shows a very long half-life, 600 00:24:26.506 --> 00:24:31.068 so the time that it needs to actually have at least... 601 00:24:31.312 --> 00:24:34.513 its concentration into the environment within a certain period of time. 602 00:24:34.673 --> 00:24:36.571 Usually we use 180 days, 603 00:24:36.614 --> 00:24:38.052 it's a bit the standard, 604 00:24:38.552 --> 00:24:40.896 or bioconcentration factor in fish. 605 00:24:41.396 --> 00:24:46.458 So how much actually this can concentrate when the fish is exposed to a substance. 606 00:24:46.997 --> 00:24:49.169 And if those limits are exceeded, 607 00:24:49.263 --> 00:24:52.169 this means that they are very persistent and very biocumulative. 608 00:24:53.122 --> 00:24:53.560 As usual, 609 00:24:53.591 --> 00:24:57.638 also this relies on so-called weight of evidence because we can have... 610 00:24:57.880 --> 00:25:02.404 multiple simulation studies or bioaccumulation tests according to the CLP criteria. 611 00:25:02.924 --> 00:25:09.853 And it is the task of the committee to weigh all the data and to decide what is the best approach in a weight of evidence approach. 612 00:25:09.908 --> 00:25:11.033 This is what we do. 613 00:25:11.752 --> 00:25:16.150 It's also we need to be transparent because everybody needs to apply the criteria in the same way. 614 00:25:16.197 --> 00:25:23.259 So it's very important that we also make informed decisions that are very logical and also transparent for the users, 615 00:25:23.291 --> 00:25:23.588 actually, 616 00:25:23.589 --> 00:25:24.947 of the CLP classification. 617 00:25:26.409 --> 00:25:27.551 So what's the impact? 618 00:25:27.611 --> 00:25:30.594 What does this mean for industry and regulators going forward? 619 00:25:31.356 --> 00:25:31.594 Well, 620 00:25:31.614 --> 00:25:33.395 we expect more proposals, 621 00:25:33.438 --> 00:25:34.395 as I mentioned to you, 622 00:25:34.739 --> 00:25:36.199 covering new hazard classes. 623 00:25:36.496 --> 00:25:42.903 And we also expect that the industry could gain actually knowledge through what RAC is doing, 624 00:25:43.012 --> 00:25:46.106 because also they will have to apply actually the very same criteria. 625 00:25:46.965 --> 00:25:50.387 And this will also result in labeling requirements. 626 00:25:50.434 --> 00:25:54.871 So we see a benefit in terms of increased consistency in hazard. 627 00:25:55.325 --> 00:25:56.105 identification. 628 00:25:56.886 --> 00:26:00.306 And RAC being the first actually to implement those criteria, 629 00:26:01.385 --> 00:26:06.150 I think the outcome of it will be fundamental to really decide how those criteria should be applied. 630 00:26:06.611 --> 00:26:07.408 And at the end of the day, 631 00:26:07.409 --> 00:26:09.486 it will be for the benefit of member state, 632 00:26:09.549 --> 00:26:10.150 commission, 633 00:26:10.447 --> 00:26:10.931 industry, 634 00:26:11.072 --> 00:26:12.767 and interested parties at large. 635 00:26:12.861 --> 00:26:13.705 And as usual, 636 00:26:14.236 --> 00:26:16.470 we send our opinions to the European Commission, 637 00:26:16.486 --> 00:26:17.783 and then with member states, 638 00:26:17.845 --> 00:26:22.345 they decide whether it deserves to be included and become an obligatory classification, 639 00:26:22.346 --> 00:26:23.689 of what we call harmonized. 640 00:26:24.817 --> 00:26:25.037 Okay, 641 00:26:25.117 --> 00:26:25.297 well, 642 00:26:25.698 --> 00:26:28.801 what's left to say except congratulations on this first milestone. 643 00:26:29.262 --> 00:26:30.622 Maybe still to wrap this up. 644 00:26:30.684 --> 00:26:35.087 So the committee has taken a very big step by applying the new hazard classes for the first time, 645 00:26:35.524 --> 00:26:36.712 classifying this substance, 646 00:26:36.727 --> 00:26:38.407 which I'm not even going to attempt to pronounce, 647 00:26:39.133 --> 00:26:41.126 as a very persistent and very bioaccumulative. 648 00:26:41.157 --> 00:26:46.860 So this now sets the tone for future decisions with more proposals expected next year, 649 00:26:47.407 --> 00:26:48.938 including endocrine disruption. 650 00:26:49.594 --> 00:26:50.141 For industry, 651 00:26:50.317 --> 00:26:53.380 It means getting ready for updated labeling and for regulators, 652 00:26:53.560 --> 00:26:54.460 more consistency, 653 00:26:54.582 --> 00:26:54.863 I guess, 654 00:26:54.960 --> 00:26:57.164 could be said than in hazard identification. 655 00:26:57.863 --> 00:26:59.707 We've actually come to the end of our episode. 656 00:26:59.808 --> 00:27:00.871 So again, 657 00:27:00.964 --> 00:27:03.113 thank you very much for taking the time right after, 658 00:27:03.246 --> 00:27:04.292 fresh from the committee meetings. 659 00:27:04.308 --> 00:27:05.011 Thank you, 660 00:27:05.152 --> 00:27:05.371 Adam. 661 00:27:05.394 --> 00:27:06.253 It's always a pleasure. 662 00:27:06.558 --> 00:27:06.933 Thank you. 663 00:27:07.558 --> 00:27:12.183 Stay tuned for further updates in our upcoming episodes and by subscribing to our news. 664 00:27:12.636 --> 00:27:13.636 As mentioned at the start, 665 00:27:13.933 --> 00:27:19.308 do take the opportunity to send us your questions and topic suggestions so we can cover them in our future episodes. 666 00:27:20.181 --> 00:27:23.984 You can send those to us at video at eka.europa.eu. 667 00:27:24.886 --> 00:27:25.027 Well, 668 00:27:25.425 --> 00:27:26.269 that's it for this year. 669 00:27:26.570 --> 00:27:32.257 Wishing you all happy holidays and looking forward to another year of the Safer Chemical podcast in 2026. 670 00:27:32.773 --> 00:27:33.695 Goodbye from Helsinki. 671 00:27:37.257 --> 00:27:38.960 Safer Chemicals podcast. 672 00:27:39.679 --> 00:27:41.804 Sound science on harmful chemicals.