The Nickel Institute is continuously increasing and enhancing the level of understanding of nickel and nickel compounds and their lifecycle, providing information on their safe use. As well as encouraging appropriate risk management measures, the Nickel Institute supports appropriate regulation that is based on sound science. It is also of the view that it is important to implement the Strategic Approach to International Chemicals Management (SAICM).
The durability and recyclability of nickel-containing materials allows them to make an important contribution to sustainability. At the same time, it is important to understand and manage the impact of these materials on health and the environment.
PRINCIPLES TO BE APPLIED IN EFFECTIVE CHEMICALS MANAGEMENT REGULATION
Influenced by SAICM, an increasing number of countries are in the process of strengthening their approaches to chemicals management. The Nickel Institute advocates for applying the following principles in such regulation:
Prioritising enhancing knowledge on substances and their use, rather than regulating based on uncertainties and adopting overly precautionary approaches
- Metals and other inorganic substances behave differently from organic substances. Regulators need to take account of their specificities. Only this way can chemicals management systems correctly predict hazard and risk and address these appropriately
Applying regulatory risk management measures that address those situations where a hazard leads to a risk, rather than applying them purely based on hazard
Ensuring regulatory coherence. In most jurisdictions, a ‘chemicals management system’ is a combination of a variety of regulations, which may lead to regulatory overlaps. Where different authorities are responsible for applying and enforcing the different regulations aiming to ensure chemicals management, it will require coordination and cooperation. Risk management decisions should always be based on the entire chemicals management system. The most effective and proportionate risk management option should be chosen, rather than duplicating risk management measures, making them more consistent and effective
Ensuring there should only be regulatory pressure to substitute a substance currently in use where a technically and economically feasible alternative, presenting fewer risks, exists. Otherwise, such pressure will lead to cases of regrettable substitution, i.e. where a substance is substituted for another that also has risks or lesser performance
Ensuring that chemicals management is viewed in the larger overall context. Hazardous substances are part of the response to a range of other societal needs, such as clean air, renewable energy storage as well as promoting and supporting innovation. Thus, decisions on regulatory risk management for substances should always take account of the socioeconomic implications
Allowing users the opportunity to provide information and to comment on planned regulation before applying any regulatory risk management measures. This will help design appropriate regulation and avoid any unintended consequences of the regulatory action. The Nickel Institute, with its science division NiPERA Inc., is ready to provide such inputs as required.
The Nickel Institute also works through umbrella associations – such as the globally-active International Council on Mining & Metals (ICMM) or the EU-focused Eurometaux non-ferrous metals producers and recyclers association – to monitor developments in chemicals management and inform its Members in order to facilitate compliance. We also promote understanding of the specificities of inorganic substances, such as nickel and its compounds, via these associations.