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May 10, 2022

HSE Begins Public Consultations on First Restriction Dossiers under UK REACH


By Lynn L. Bergeson and Carla N. Hutton

The United Kingdom (UK) Health and Safety Executive (HSE) announced on May 6, 2022, the beginning of a six-month public consultation on restriction proposals on lead in ammunition and substances in tattoo inks and permanent make-up (PMU). According to its press release, HSE proposed the restriction on lead in ammunition after identifying there is an unacceptable risk to human health and the environment that is not adequately controlled. HSE proposed the restriction on hazardous substances present in tattoo inks and PMU as a precautionary measure to address potential risks to human health, as there is currently no legislation in Great Britain that addresses the risks presented by insertion into the skin of these substances. In forming opinions on whether to introduce the restrictions, HSE states that it will engage with independent experts on the REACH Independent Scientific Expert Pool (RISEP), who will form a Challenge Panel to provide knowledge, scrutiny, and challenge. Comments on the restriction proposals are due November 6, 2022.

HSE published the restriction dossiers following a request from the Department for Environment, Food and Rural Affairs (Defra) Secretary of State, with agreement from the Scottish and Welsh governments. HSE notes that restrictions are developed to limit, ban, or set conditions on the manufacture, placing on the market, or use of a substance (or group of substances) that are of concern due to risks posed to human health and/or the environment.