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BeST submits feedback to GRA Survey

VVA Consortium, the European Commission's external consultant, launched a survey on the impact of the extension of the Generic Risk management Approach (GRA) in the frame of the ongoing review of REACH.


On 2 June, BeST submitted feedback to this survey, highlighting the following key points:

  • A substance proven to be safe should not fall in the scope of the GRA. Therefore, a risk-based approach should be adopted.

  • The safe use concept should be preferred as it adequately addresses the protection of human health and of the environment.

  • Where the use of a substance is proven safe, the availability of alternatives is irrelevant.

  • A coordinated framework is needed and must be supported by RMOAs to determine the most appropriate risk management option for a given substance instead of a sweeping implementation of the GRA.

To access BeST’s position paper, download the pdf file below:



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