Switzerland strengthens its ORRChem by implementing provisions from EU REACH and the POP Recast Regulation, as well as new requirements for PFHxS, its salts and PFHxS-related substances. These will be implemented in phases, starting April 1, 2022.
On March 10, 2022, Switzerland issued Official Collection 2022 162 (RO 2022 162, French, German and Italian versions) to revise its Ordinance on the Reduction of Risks Associated with the use of Particularly Dangerous Substances, Preparations and Articles (also known as Chemical Risk Reduction Ordinance, ORRChem, RS 814.81, French, German and Italian versions) to further align with Regulation (EU) 2019/1021 on persistent organic pollutants (POP recast regulation) and Annex XVII of Regulation (EC) 1907/2006 ‘Registration, Evaluation, Authorization and Restriction of Chemicals (Annex XVII of REACH) in the European Union (EU).
In addition to editorial changes, RO 2022 162 contains several important changes to Annex 1 ‘Provisions Concerning Specific Substances’ and Annex 2 ‘Provisions Concerning Specific Substances’ of ORRChem. It:
- Amends the following Annexes:
- Annex 1.1 ‘Persistent organic pollutants, POP’
- Annex 1.2 ’Halogenated organic substances’
- Annex 1.4 ‘Ozone depleting substances’
- Annex 1.5 ‘Substances stable in the atmosphere’
- Annex 1.6 ‘Asbestos’
- Annex 1.10 ‘Carcinogenic, mutagenic or reprotoxic substances, CMR substances’
- Annex 2.9 ‘Plastics, their monomers and additives’
- Annex 2.10 ‘Refrigerants’
- Annex 2.11 ‘Extinguishing agents’
- Replaces Annex 1.16 ‘Per- and polyfluoroalkyl substances, PFAS’ – in relation to:
- Perfluorooctane sulfonic acid (PFOS), its salts and PFOS derivatives
- Perfluorohexane sulfonic acid (PFHxS), its salts and PFHxS-related substances
- Perfluorooctanoic acid (PFOA), its salts and PFOA-related compounds
- Perfluorocarboxylic acids containing 9 to 14 carbon atoms in the chain (C9-C14 PFCAs), their salts and C9-C14 PFCA-related substances
- Fluoroalkylsilanols and their derivatives
Highlights of several of the aforementioned amendments and Annex 1.16 ‘PFAS’ are summarized in Table 1.
CHEMICAL RISK REDUCTION ORDINANCE, ORRCHEM | |
|---|---|
Annex to ORRChem | Highlight |
Annex 1.1 ‘Persistent organic pollutants’ |
|
Annex 1.10 ‘CMR substances’ |
|
Annex 1.16 ‘Per- and polyfluoroalkyl substances, PFAS’ | Entire Annex is replaced:
|
Annex 2.9 ‘Plastics, their monomers and additives’ |
|
Annex 2.11 ‘Extinguishing agents’ | Clarifies that Annex 1.16 applies to extinguishing agents containing PFOS, or PFOA, C9-C14 PFCAs and PFHxS as well as their related substances |
*Benzo[a]pyrene (BaP), benzo[e]pyrene (BeP), benzo[a]anthracene (BaA), chrysen (CHR), benzo[b]fluoranthene (BbFA), benzo[j]fluoranthene (BjFA), benzo[k]fluoranthene (BkFA) and dibenzo[a,h]anthracene (DBAhA) | |
Table 1
CHEMICAL RISK REDUCTION ORDINANCE, ORRCHEM | |||
|---|---|---|---|
Entry | Substance | Scope | Requirement |
1 | PFOS and its derivatives |
| Prohibited |
| < 10 mg/kg | ||
| ≤ 1000 mg/kg | ||
| ≤ 1 µg/m² | ||
2 | PFHxS and its salts PFHxS-related substances |
| Prohibited |
| ≤ 25 ppb PFHxS | ||
3 | PFOA and its salts |
| Prohibited |
| ≤ 25 ppb | ||
4 | PFOA-related compounds |
| Prohibited |
| ≤ 1000 ppb (sum) | ||
5 | C9-C14 PFCAs and their salts |
| Prohibited |
| ≤ 25 ppb | ||
6 | C9-C14 PFCA-related substances |
| Prohibited |
| ≤ 260 ppb (sum) | ||
**Contains certain derogations, including:
| |||
Table 2
It is interesting to note that Switzerland regulates perfluorohexane sulfonic acid (PFHxS), its salts and PFHxS-related substances (Annex 1.16), a measure that is under consideration in the Stockholm Convention and the European Union (EU).
According to RO 2022 162, there are several effective dates:
- April 1, 2022, for provisions other than those indicated below
- October 1, 2022, for Annex 1.16 ‘PFAS’
- April 1, 2023, for amendments to the Plant Protection Products Ordinance of May 12, 2010
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