David Park, British Coatings Federation, discusses the recent developments in UK REACH and the BCF’s Net Zero Roadmap
The previous PPCJ column from the British Coatings Federation focussed on the problems with the UK’s approach to establishing its own version of REACH. There was the need to maintain high standards of environmental protection and human health and safety, of course, but for this to be done in a way that did not simply cut and paste all EU requirements into legislation for the UK. That approach would be of huge cost to industry, damage the UK’s manufacturing base, and create so much bureaucracy in replicating datasets the regulator would have little time to actually work on compliance. That is why Defra – the Government Department in charge of chemicals policy in the UK – had extended the deadline for the registration of substances, in order to allow time to come up with a new approach.
I am pleased to report that since then – just a couple of weeks ago in fact – Defra set out a new policy direction for UK REACH. In a written statement they confirmed they would not generally require full hazard data dossiers to be submitted for each substance being registered. Indeed, they would look to ensure only the bare minimum of hazard data was required. There might be exceptions – for example of substances of very high concern, or where UK regulators want to look in more detail at particular substances for their own reasons. And in such cases industry might be expected to supply the required extra information at short notice.
While less hazard data will be required, the UK regulator, the Heath and Safety Executive (HSE) will instead require more risk data, in the form of use and exposure data in the workplace. The HSE has been very clear for some time that they want this information to establish how substances are being used specifically in the UK and that this will help them fulfil their role more effectively. At the present time, it is unclear how much use and exposure data will be required, although it seems a tiered approach may operate with more data needed where use of a substance exceeds 10 tonnes, for instance. Importantly for our members, as formulators and downstream users of chemicals, is who will be expected to gather and provide the data and how it will be fed into the registration process. We need to ensure that the process is proportionate and workable.
More information will be published in February, when a formal consultation process will begin. There will also be a separate consultation in January which will cover new proposals for the fee levels for UK REACH. The British Coatings Federation looks forward to continuing to engage with the UK Government on this important issue and playing our role in making sure we get such an important policy area right.
A Net Zero Roadmap for the UK coatings sector
On top of the REACH announcement, November has been a busy month for the BCF in other ways. We have spent several months working with our members to produce a Net Zero Roadmap for the UK coatings sector and were glad to finally launch the finished product at a special Net Zero focussed seminar on 14th November. You can read the Roadmap here.
The purpose of the Roadmap was fourfold.
- To provide background and context to Net Zero legislation and requirements;
- To set out the important role that coatings have to play in helping the world meet Net Zero targets;
- To set an initial estimated baseline for carbon emissions for the whole UK coatings sector, against which to measure future progress;
- And, perhaps most importantly, to provide members with guidance, tools, resources and links to help them set and pursue their own Net Zero targets.
We know that many of BCF’s larger members are already well advanced along their Net Zero journey. Indeed, there are many excellent corporate leaders in this regard. However, we also know that Net Zero is perhaps more difficult for SMEs to tackle. This is why we have also produced a shorter ‘Quick Start Guide’ alongside the main document, focussing on the most salient guidance that smaller companies can use to get up and running. We want our Roadmap – this version and future iterations – to be a practical method of support for our members.
One of the report findings was just how much of the sector’s emissions falls into the ‘scope 3’ category. These are emissions beyond the direct control of a business – e.g. its own energy usage – but are created either upstream or downstream its supply chain. In particular, the emissions created upstream from raw material extraction and processing are particularly high. In all, BCF’s initial estimate is that a massive 98% of the sector’s emissions call into the scope 3 category.
That being said, we know we must look to tackle the scope 1 and 2 emissions as well. And even though scope 3 emissions are harder to control, members realise they need to work with their supply chains to influence a reduction in emissions upstream and downstream. If that does not happen, the Net Zero journey will never be completed. That is why the Roadmap was launched as part of a successful day-long seminar which focussed on measuring and tackling scope 3 emissions and encouraging those conversations with suppliers and customers.
This is the first time a document like this has been attempted for our industry in the UK and we recognise it is just a start. The Roadmap will be updated regularly to hone emissions data for the sector, measure progress and provide updated guidance to members as appropriate.