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The UK Health and Safety Executive (HSE) recently published the Work Program (2024/25), which sets out the activities that the HSE will carry out this work year to operate the UK regulation on the Registration, Evaluation, Authorisation and Restriction of Chemicals (UK REACH). Major objectives are summarized below.
SVHC Identification
HSE will conduct an initial assessment of substances submitted for Substances of Very High Concern (SVHC) identification under EU REACH in 2023/24. Target substances are shown in table below. This activity aims to determine if they are appropriate for SVHC identification under UK REACH, thereby considering if the Regulatory Management Options Analysis (RMOA) should be initiated.
Substances Subject to Assessment for SVHC Identification | EC Number | CAS Number | Reason for Inclusion on SVHC List of EU REACH |
Oligomerisation and alkylation reaction products of 2-phenylpropene and phenol | 700-960-7 | / | vPvB |
Bumetrizole | 233-445-4 | 3896-11-5 | vPvB |
2-(dimethylamino)-2-[(4-methylphenyl)methyl]-1-[4-(morpholin-4-yl)phenyl]butan-1-one | 438-340-0 | 119344-86-4 | Toxic for reproduction |
2-(2H-benzotriazol-2-yl)-4-(1,1,3,3-tetramethylbutyl)phenol | 221-573-5 | 3147-75-9 | vPvB |
Diphenyl (2,4,6-trimethylbenzoyl)phosphine oxide | 278-355-8 | 75980-60-8 | Toxic for reproduction |
Bis(4-chlorophenyl) sulphone | 201-247-9 | 80-07-9 | vPvB |
In addition, HSE also undertakes assessment of PFAS used as processing aids to consider if SVHC identification is appropriate in UK REACH. For substances identified to be SVHCs, they will be added to the Candidate List and may be recommended for inclusion on the Authorisation List of UK REACH.
ROMAs to be Completed and Initiated
RMOA is a core procedure of UK REACH, used to systematically assess and manage chemical substances that may pose risks to human health or the environment. It provides a scientific basis for the management of high-risk chemicals by integrating scientific evidence, stakeholder engagement, and transparent decision-making mechanisms, while achieving balance between economic costs, social benefits, and industrial feasibility. Based on the ROMA recommendations, risk management measures will be imposed, such as restrictions and autorisations.
According to the Work Program (2024/25), HSE will complete technical assessment on the ROMAs initiated in 2023/24, including:
Formaldehyde and formaldehyde releasers in articles: Existing restriction under EU REACH in place.
Siloxanes (D4, D5, and D6): Being recommended for inclusion in Authorisation List of EU REACH and potential EU REACH restriction.
Bisphenol in thermal paper: Existing restriction under EU REACH for bisphenol A in thermal paper; consideration of substances that can be used as alternatives to bisphenol A in thermal paper.
HSE will also carry out two new ROMAs in 2024/25, targeting two SVHCs identified under EU REACH and recommended for inclusion in Authorisation List of EU REACH:
2-(4-Tert-butylbenzyl)propionaldehyde and its individual stereoisomers (Lysmeral)
2,4,6-tri-tert-butylphenol (2,4,6-TTBP)
Restriction Proposals
HSE will set conditions for the placing on the market, and use of PFAS in firefighting foam (FFF), considering risk management throughout the lifecycle. The preparation of its restriction dossier is expected to be completed by March 2025.
Engaging with stakeholders, HSE will also prepare restriction proposals for the following:
By March 2025: Wide dispersive uses of PFAS such as the application of coatings or use of cleaning agents.
By 2025/26: Residues of 1,4 dioxane that may be present in surfactants.
By 2026/27: Manufacture and placing on the market of consumer articles from which PFAS are likely to be released into air, water or oil, or directly transferred to humans.
