3E EH&S Expressions Blog

3E EH&S Expressions is our forum for sharing our latest musings and observations on the ever-evolving EH&S regulatory compliance landscape. Here we will be introducing you to some of 3E’s most prolific and valued subject matter specialists weighing in on some of the more complex and time-consuming issues affecting our industry today, including TSCA Reform, REACH, GHS, Conflict Minerals and more.

April 21, 2017Kirsten Wallerstedt and Scott Stephens

Since the beginning of 2017, the EU has harmonized information for poison centers, Britain formally invoked Article 50 to leave the EU, SVHCs are proposed to be targeted in the waste directive, conflict minerals is one step from becoming official, and a new medical devices framework is moving forward.

April 13, 2017Kirsten Wallerstedt

Conflict minerals and responsible sourcing requirements have become an enduring part of doing business. Beyond the U.S. law, the EU has passed a conflict minerals regulation, private companies such as Apple and Google are independently dedicated to requiring responsible sourcing in their supply chains, and the U.S. has sanctions in...

April 5, 2017Kami Blake

Can product compliance be managed proactively? As the requirements expand up and down the supply chain and throughout the product lifecycle, the organizational responsibilities have moved beyond traditional EHS disciplines. Supplier conformance is now intricately entangled with upstream material compliance, and one without the other may ultimately end in vendor...

March 3, 20173E Regulatory Research Team

The Turkish Ministry of Environment and Urbanization has released a new draft of its proposed REACH-like regulation, KKDIK. While the government has not announced an official timeline for final implementation, it is expected to be finalized in the first quarter of 2017.

February 27, 2017Kirsten Wallerstedt

ECHA is currently consulting on four applications for authorization, two testing proposals, and has two open calls for comments and evidence. The substances at issue are: sodium dichromate, chromium trioxide, nickel and its compounds, polycyclic organic hydrocarbons, and the substance with EC Number 941-357-0. The deadlines for comments range from 27 March 2017 to 19 April 2017.

February 17, 2017Kirsten Wallerstedt

On 24 January 2017, the European’s Parliamentary International Trade Committee (INTA) voted overwhelmingly to support the EU’s conflict minerals proposal, with a vote of 39 in support, none opposed, and two abstentions. The Regulation sets up a Union system for supply chain due diligence for importers of tin, tantalum and tungsten, their ores, and gold originating in conflict-affected and high-risk areas. The Regulation, if finalized, is expected to become enforceable on 1 January 2021.

January 20, 2017Bernie Henn

On January 12, 2017, the European Chemical Agency (ECHA) added four new Substances of Very High Concern (SVHC) to the REACH Candidate List for Authorization.

January 18, 2017Written by Jomarie Garcia; Edited by Julie Byrne and Kirsten Wallerstedt

The U.S. Environmental Protection Agency (EPA or Agency) announced on 13 January 2017 the long-awaited proposal for the chemical inventory reset under the Toxic Substances Control Act (TSCA). Comments on the proposed rule will be accepted until 14 March 2017.

January 11, 2017Kirsten Wallerstedt

On 28 December 2016, Korea’s Ministry of Environment (MoE) proposed MoE Public Notice No. 2016-869, revising the Act on Registration and Evaluation of Chemical Substances (K-REACH). The proposed changes would impose stricter controls on chemicals.

December 20, 2016Xiaolu Wang

The State Council of the People's Republic of China issued the "Comprehensive Action Plan on the Safety Control of Hazardous Chemicals" (危险化学品安全综合治理方案) (the Action Plan) on 29 November 2016. The Action Plan aims to further strengthen the decisions and policies regarding safety management of hazardous chemicals, in light of the explosion accident that occurred in Tianjin last year. The Action Plan does not impose any direct requirements on individual facilities. Instead, it provides guidelines and goals for government agencies responsible for safety supervision of hazardous chemicals in China. Specifically, the Action plan outlines 40 major enforcement actions to be taken by relevant authorities from December 2016 to November 2019. It also provides targeted deadlines for each individual enforcement action. The Action Plan has an impact on facilities that produce, store, use, sell, import, transport, or dispose of hazardous chemicals.