technical guidance documents - Institute for Health and Consumer ...
technical guidance documents - Institute for Health and Consumer ...
technical guidance documents - Institute for Health and Consumer ...
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APPENDIX XIII<br />
Appendix XIII Risk assessment of sources not covered by the life-cycle of the<br />
substance<br />
Introduction<br />
Exposure may occur from other sources than the life-cycle of the produced or imported<br />
substance under assessment. Such sources have been referred to as “unintentional sources”.<br />
Examples are substances of natural origin, substances <strong>for</strong>med in combustion processes <strong>and</strong><br />
indirect emissions of the substance, e.g. as by-product, contaminant or degradation product of<br />
another substance. In these cases in<strong>for</strong>mation is necessary on emissions which are not covered<br />
by the life-cycle of the substance being assessed.<br />
Knowledge of the extent of the sources not covered by the life-cycle of the substance under<br />
review is necessary <strong>for</strong> a full evaluation of the risks posed by the priority existing substance or<br />
biocidal product. The in<strong>for</strong>mation is needed <strong>for</strong> example <strong>for</strong> a correct interpretation of measured<br />
environmental concentrations. The in<strong>for</strong>mation is also required <strong>for</strong> an evaluation of the relative<br />
contribution of the emissions of the substance under review to the overall risks posed by the<br />
substance through all possible sources. Such in<strong>for</strong>mation might be relevant in the eventual<br />
development of a risk reduction strategy.<br />
In this appendix some recommendations are given on how to deal with these kind of sources,<br />
based on the practical experience gained with the implementation of the ESR. There is still a<br />
need <strong>for</strong> an EU decision on how to h<strong>and</strong>le these cases at the time of revision of the TGD.<br />
Legal background<br />
The Existing Substances Regulation (EEC) 793/93 (ESR) requires that all in<strong>for</strong>mation needed to<br />
carry out the risk assessment of a priority substances is submitted to the rapporteur by the<br />
Producers <strong>and</strong> Importers of the substance. The risk assessment however is one of a selected<br />
priority substance, the sources of which can be from the produced <strong>and</strong> imported substance, but<br />
also from other sources. Commission Regulation (EC) 1488/94 <strong>for</strong> example <strong>for</strong>esees that the risk<br />
assessment of a priority substance entails an exposure assessment which, in particular is to<br />
consider the exposures resulting from the life-cycle of the produced <strong>and</strong> imported priority<br />
substance, but need not do so exclusively. The Biocidal Products Directive (98/8/EC) (BPD)<br />
states that cumulation of effects from the biocidal products containing the same active<br />
substances shall be taken into account, where relevant, in the assessment of a biocidal active<br />
substance.<br />
Recommendation <strong>for</strong> sources not covered by the life-cycle of the substance<br />
The rapporteur should clearly list other sources, which can give rise to exposure by the substance<br />
being assessed. The risk assessment should include as much readily available in<strong>for</strong>mation on<br />
these sources as possible. Whether or not this in<strong>for</strong>mation can be taken into account in the risk<br />
characterisation is dependent on the quantity <strong>and</strong> quality of the available in<strong>for</strong>mation. If there is<br />
not sufficient confidence in the available database to make a conclusion of concern/no concern,<br />
the risk assessment should be finalised with the conclusion “further in<strong>for</strong>mation is needed”<br />
(Conclusion (i)).<br />
If the emissions originate from the life-cycle of another substance that can be prioritised under<br />
the ESR (i.e. a substance listed in EINECS), it is not required to take these sources into account<br />
in the risk characterisation, as they can be covered by prioritising the other substance. If the<br />
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