Submission of Information on ALTERNATIVES (NON-CONFIDENTIAL)
Submission of information on
Template
for third party submission of information on alternatives for
Applications for Authorisation
non-confidential
Legal name of submitter(s): International Chemical Secretariat
Norra Allégatan 5
SE-402 31 Gothenburg
Sweden
Table of CONTENTS
1. alternative ID and properties 3
2. Technical feasibility 3
3. Economic feasibility 3
4. Hazards and risks of the alternative 3
5. Availability 3
6. Conclusion on suitability and availability of the Alternative 3
7. other comments 3
References 3
APPENDIXES 3
1. alternative ID and properties
[Insert text here]
2. Technical feasibility
[Insert text here]
3. Economic feasibility
[Insert text here]
4. Hazards and risks of the alternative
[Insert text here]
5. Availability
[Insert text here]
6. Conclusion on suitability and availability of the Alternative
[Insert text here]
7. other comments
ChemSec consider the handling of these first authorisation application as test case for future submissions and therefore call upon ECHA to take all the necessary steps to ensure that the process will be as effective and transparent as possible in order to deliver on the REACH objectives to substitute SVHCs by safer alternatives.
Lead sulfochromate yellow is a classified CMR (Class I & II) according to Annex 1 of Directive 67/548/EEC. Lead interferes with a variety of body processes and is toxic to many organs and tissues including the heart, bones, intestines, kidneys, and reproductive and nervous systems. ChemSec believes that the use of lead-paints is an unnecessary source of toxic lead in the environment. E.g. alternatives such as water-based, lead-free traffic paint are readily available today (http://en.wikipedia.org/wiki/Lead_paint)
References
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APPENDIXES
[Insert text here]
[insert consultation number] [insert non-confidential generic name of the alternative substance/mixture or description of the alternative technology] [insert date of submission]
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