Fifteen Substances of Very High Concern
The fifteen substances are: Anthracene oil; Anthracene oil, anthracene paste, lght fractions from distillationi; Anthracene oil, anthracene paste, anthracene fraction; Anthracene oil, anthracene-low; Anthracene oil, anthracene paste; Coal tar pitch, high temperature; Acrylamide; Aluminiosilicate, Refractory Ceramic Fibres; Zirconia Aluminosilicate, Refractory Ceramic Fibres; 2,4-Dinitrotoluene; Diisobutyl phthalate; Lead chromate; Lead chromate molybdate sulphate red (C.I. Pigment Red 104); Lead sulfochromate yellow (C.I. Pigment Yellow 34); Tris(2-chloroethyl)phosphate.
Theses substances were proposed to ECHA by EU Member States and by the European Commission. The public has until October 15 to provide comments, in particular focusing on why these chemicals should or should not be deemed SVHC.
After the public comment period closes, ECHA’s Member States Committee will decide whether these substances should be placed on the Candidate List.
Once a substance is placed on the Candidate List, a manufactured or importer of an article that contains that substance in an amount greater than 0.1% has an obligation to notify its customers by providing the name of the substance and sufficient available information to ensure safe use of the article.
Further, once a substance has been placed on the Candidate List, it may eventually be subjected to Authorization and/or banned.
From a Goodrich perspective, Goodrich should perform the same type of analysis that it did with the original 15 substances that are already on the Candidate List and be prepared to respond to customer inquiries regarding same. Goodrich should also consider whether any of these substances is so critical to its business that comments, most likely through the ASD, would need to be submitted before October 15. Finally, Goodrich should think about whether it needs to begin considering identifying substitutes for these substances.
