An admirable presentation by Jack de Bruijn, Director of Risk Management, ECHA, at the NGO-ECHA discussion platform on substitution held September 25, 2013. De Bruijn correctly identifies that it is a company decision on whether or not it can substitute another chemical or technology for a substance of very high concern or that has been restricted.  He stated it's ECHA's job to ensure REACH risk communication and management occurs throughout the stream of commerce.  He showed this slide on the many nontrivial factors that go into making substitution decisions:

p4 de Bruijn

Product stewardship requires consideration of all these factors and making sure adequate risk management occurs regardless of which chemicals are being used.  Sometimes switching to substitutes achieves the best risk reduction for the least pain.  Mindless substitution ("just find something that's not on a list!") often results in worse overall risks and adverse social and economic consequences.

The full minutes of the NGO-ECHA meeting are here.

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