COMMENTS ON AN ANNEX XV DOSSIER FOR IDENTIFICATION OF A SUBSTANCE AS SVHC AND RESPONSES TO THESE COMMENTS

Substance name:	Trilead bis(carbonate) dihydroxide	
CAS number:	1319-46-6	
EC number:	215-290-6	

The substance is proposed to be identified as meeting the following SVHC criteria set out in Article 57 of the REACH Regulation: Repr. 1A

Disclaimer: Comments provided during public consultation are made available in this document as submitted by the commenting parties. It was in the commenting parties own responsibility to ensure that their comments do not contain confidential information. The Response to Comments table (RCOM) has been prepared by the European Chemicals Agency. RCOM has not been agreed by the Member State Committee nor has the document been modified as result of the MSC discussions. The table does not contain any confidential information.

PART I: Comments and responses to comments on the SVHC proposal and its justification

General comments on the SVHC proposal
Number	Date	Submitted by (name, Organisation/
MSCA)	Comment	Response	
18	2012/10/18	Industry or trade association
Belgium	Page 10 indicates that ECHA has not carried out further analysis of this information. The first consultation gives the opportunity to provide additional information on lead compounds to indicate whether the justification is correct (part I) and whether authorization under REACH provides the right Risk Management Option given the fact that several EU directives exist aiming on prohibition and substitution of lead compounds (part 2). The specific comment fields below have been filled where appropriate.	Thank you for your comment and the additional information provided. 

Please note that the SVHC identification process, as set out in REACH Article 59(1) is intended to identify substances meeting the criteria referred to in Article 57 and establishing a candidate list of substances for eventual inclusion in Annex XIV.
Hence, no further precondition than meeting criteria referred to in Article 57 needs to be fulfilled in order to include a substance in the candidate list in accordance with the procedure set out in Article 59. 

The current proposal only concerns identifying the substance as a substance of very high concern (SVHC) in accordance with REACH Article 59(2). However, if the substance is identified as SVHC, information in relation to controls under other legislation, use, exposure, alternatives and risks will be taken account of at later stages of the authorisation process.

Even though information provided during public consultation is taken into account, we would like to stress that the registrations are the standard tool and route to communicate information on a substance and its uses to the authorities The registrations are the authorities’ principal source of information when assessing the need of further risk management for a substance or (some of) its uses. Therefore, it is of utmost importance that registrants keep the information provided in the registration dossiers up to date and adequately describe the current use and exposure situation, including the operational conditions and risk management measures in place.
If certain uses are not covered by the provided exposure scenarios, downstream users can either communicate this through supply chain communication (via their suppliers) to the registrants, who then need to update their registrations accordingly, or prepare their specific chemical safety report and submit a downstream user report to ECHA.

Topics such as the availability and suitability of alternatives, socio-economic considerations regarding the benefits of a use or the (adverse) impacts of ceasing a use as well as information on the low level of risk associated to a use are important. Information regarding these topics should be provided as part of the application for authorisation (e.g. in the analysis of alternatives, the chemical safety report or the socio-economic analysis). This information will be taken into account by the Risk Assessment and Socio-Economic Analysis Committees when forming their opinions and by the Commission when taking the final decision. It may impact the decision on granting the applied for authorisation and the conditions applicable to the authorisation, such as e.g. the length of the time limited review period of the authorisation.	
			See also:
Comment 18 attachment (20121016_FINAL_Position_REACH_Consultation.pdf).pdf		
17	2012/10/18	International NGO
Health and Environment Alliance
Belgium	We support the adoption of this chemical to the Candidate List.	Thank you for providing your opinion.	
16	2012/10/18	Company
Austria	This substance shall not be added to the candidate list, unless an exposure scenario and related risk assessment is indicating a risk to health and environment and interferences with existing legislation restricting lead and scrutiny for other risk management options has been applied. Binding Occupational Exposure Limit (OEL) for lead already exists in the EU.	Thank you for your comment. Please refer to response to comment #18 in this section.	
			See also:
Comment 16 attachment (Position_REACH_Consultation.pdf).pdf		
13	2012/10/18	Company
Netherlands	Martens kunststoffen b.v. fully supports and subscribes ti the comments made by ILA	Thank you for your comment. The International Lead Association and the Pb REACH Consortium did not provide comments on this substance. 	
12	2012/10/18	International organisation
ASD AeroSpace and Defence Industries Association of Europe
Belgium	None. The dossier does indicate that the substance meets
 the  requirements of an SVHC.	-	
11	2012/10/18	Member State
Norway	It is recognised globally that lead and its compounds pose a significant risk to human health and the environment and that there remains a need for a continued focus on reducing the risks posed by these substances. The concerns for lead compounds are their reprotoxic/neurotoxic properties. The Committee for Risk Assessment under REACH has stated that no threshold for the adverse effect of lead has been identified in humans.  We would also like to stress that the long lasting harmful effects to the environment are of serious concern (cf. classification of lead compounds in general and a number of specific lead compounds in CLP concerning environmental hazard;  "Aquatic Acute 1" ("Very toxic to aquatic life") and  "Aquatic Chronic 1" ("Very toxic to aquatic life with long lasting effects"). 

The Norwegian CA supports that trilead bis(carbonate)dihydroxide (basic lead carbonate) should be identified as a substance of very high concern and should be included in the Candidate List.	Thank you for providing your opinion.	
10	2012/10/18	Company
Britannia Refined Metals Ltd.
United Kingdom	Britannia Refined Metals Ltd. is a member of the International Lead Association and the Pb REACH Consortium. ILA has provided a consolidated response on behalf of members of the Pb REACH consortium. As a consequence, Britannia Refined Metals Ltd. fully supports and subscribes to the comments made by ILA.	Thank you for your comment. The International Lead Association and the Pb REACH Consortium did not provide comments on this substance. 	
9	2012/10/18	Company
Germany	The substances shall not be added to the candidate list, unless an exposure scenario and related risk assessment is indicating a risk to health and environment and interferences with existing legislation restricting lead and scrutiny for other risk management options has been applied. Binding Occupational Exposure Limit (OEL) for lead already exists in the EU.	Thank you for your comment. Please refer to response to comment #18 in this section.	
			See also:
Comment 9 attachment (Position_REACH_Consultation.pdf).pdf		
8	2012/10/18	Member State
Belgium	The BE MSCA supports this proposal  from ECHA to identify  the substance as SVHC as the proposal is based on article 57 (c) of the REACH Regulation. We regret however the very limited amount of information available in the dossiers.	Thank you for providing your opinion.	
7	2012/10/17	National NGO
Naturskyddsföreningen, Swedish Society for Nature Conservation (SSNC)
Sweden	The Swedish Society for Nature Conservation (SSNC) supports the proposal to categorise Trilead bis(carbonate)dihydroxide (basic lead carbonate) as a Substance of Very High Concern.
 
The SSNC is the largest and most influential environmental organisation in Sweden, currently with 192,000 members nationwide. The SSNC works to protect the natural environment and human health, and to strengthen global solidarity.	Thank you for providing your opinion.	
14	2012/10/17	Industry or trade association
ELSA (ESPA)
Belgium	To our astonishment there has been no analysis of the information provided in the registration dossier of this substance. ELSA is of the opinion that such information has to be taken into account. Therefore we have inserted an attachment in Section IV of the commenting form. 	Thank you for your comment.

ECHA has received a request from the Commission in accordance with REACH Article 59(2) to prepare an Annex XV dossier proposing the identification of this substance as SVHC.

Preparation of a risk management options analysis (RMOA) before proposing the identification of a substance as SVHC is a voluntary step in the co-ordination of risk management activities among the Competent Authorities for REACH but not a requirement of REACH. 

Nevertheless, ECHA agrees on the importance of identifying the most appropriate route(s) for risk management and on the co-operation and co-ordination of the regulatory risk management activities between the authorities. 

The RMOA submitted by the German CA will be taken into consideration before further risk management activities for this substance, beyond identification as SVHC, are initiated.

The current proposal for identifying the substance as a substance of very high concern (SVHC) is in accordance with REACH Article 59(2) based on its harmonised classification in Annex VI of Regulation (EC) No 1272/2008 (CLP Regulation). The additional mentioned information is not relevant for determining whether the substance meets the criteria for identification as SVHC. However, when examining whether the substance should be recommended for inclusion in Annex XIV, ECHA will indeed have to assess available information on uses and exposures. In addition, information on work already done by industry to identify and assess potential alternatives is used in defining transitional arrangements in the draft Annex XIV entries for the recommended substances. This information will be collected by ECHA before prioritising the substances and defining the transitional arrangements for its recommendation. The generic approaches for prioritisation and defining the draft Annex XIV entries are available at: http://echa.europa.eu/documents/10162/13640/axiv_prioritysetting_general_approach_20100701_en.pdf and http://echa.europa.eu/documents/10162/13640/draft_axiv_entries_gen_approach_4th_en.pdf
If ECHA intends to recommend the substance for Annex XIV inclusion, interested parties can provide comments on ECHA’s recommendation, including the suggested transitional arrangements in accordance with Article 58 of REACH.

If the substance is identified as SVHC, topics such as the availability and suitability of alternatives, socio-economic considerations regarding the benefits of a use or the (adverse) impacts of ceasing a use as well as information on the low level of risk associated to a use are important. Information regarding these topics should be provided as part of the application for authorisation (e.g. in the analysis of alternatives, the chemical safety report or the socio-economic analysis). This information will be taken into account by the Risk Assessment and Socio-Economic Analysis Committees when forming their opinions and by the Commission when taking the final decision. It may impact the decision on granting the applied for authorisation and the conditions applicable to the authorisation.	
			See also:
Comment 14 attachment (SVHC-Public-Consultation-Oct-2012_ELSA-comments_CAS-1319-46-6.pdf).pdf		
15	2012/10/17	Company
Robert Bosch GmbH
Germany	See Attachment	Thank you for your comment. Please refer to response to comment #18 in this section.	
			See also:
Comment 15 attachment (Bosch-Contribution-for-Stakeholder-for-ECHA-lead.pdf).pdf		
6	2012/10/17	Industry or trade association
Divison of Electronic Components and Systems in ZVEI
Germany	The substances shall not be added to the candidate list, unless an exposure scenario and related risk assessment is indicating a risk to health and environment and interferences with existing legislation restricting lead and scrutiny for other risk management options has been applied. Binding Occupational Exposure Limit (OEL) for lead already exists in the EU.	Thank you for your comment. Please refer to response to comment #18 in this section.	
			See also:
Comment 6 attachment (20121016_FINAL_Position_REACH_Consultation.pdf).pdf		
5	2012/10/16	National NGO
IEW
Belgium	We support the nomination of this chemical to the Candidate List as a substance of very high concern	Thank you for providing your opinion.	
4	2012/10/11	Member State
Germany	According to REACh Regulation it is formally correct to identify substances as SVHC based on their CMR classification listed in Annex VI of the CLP directive solely. However, up to now MS have provided some specific information to identify concerns. Therefore, the instrument of preparing RMOA prior to annex XV preparation has been established e.g. to avoid duplicate work. The German CA would appreciate to continue this practice. This guarantees that relevant substances are prioritised.

Referring to the Risk Management Option Analysis (RMOA) concerning “Lead compounds in PVC-products” carried out and submitted by the German CA we want to comment on the proposal for identification as SVHC of the following substances:

Neutral lead stearate (91031-62-8)
Dibasic lead stearate (12578-12-0)
Dibasic Lead Phthalate (69011-06-9)
Trilead Dioxide Phosphate (12141-20-7)
Tetralead Trioxide Sulphate (12202-17-4)
Pentalead Tetraoxide Sulphate (12065-90-6)
Basic Lead Carbonate (1319-46-6)
Sulfurous Acids, lead salt, dibasic (62229-08-7)

After evaluation of the above mentioned substances, the derivation of their use in the production of PVC-products and extensive discussion with the European stabiliser producers  the RMOA drew the conclusion that no action for these substances concerning the use in PVC is necessary at the moment. As conducted in the RMOA-document, industry has initiated a community-wide self-commitment aiming at the complete phase-out of lead in PVC-products by 2015. The transparency and reliability of the commitment were ensured as the progress was accompanied and rated by independent experts as well as by the EU-commission.

One principle on which Regulation (EC) No. 1907/2006 is based is that manufacturers, importers or downstream users should ensure that their substances have no adverse effects on human health and the environment (article 1(3)) by precautionary action. From the German CAs point of view the European initiative (Vinyl2010, followed by VinylPlus) has taken this responsibility by traceable reducing the use of lead and the introduction of alternatives. Therefore, the German RMOA concluded that the best measure at the moment was to accompany the progress until 2015 and initiate an Annex-XV-process for restriction in case the self-commitment does not reach its desired goals.

The German CA is aware that the substances concerned in this comment as well as the RMOA are not solely used in plastic products. Tetralead trioxide sulphate and pentalead tetraoxide sulphate are used in lead acid battery production, also. Nevertheless, Germany wants to point out some aspects regarding recycling are of importance once the substances are listed in the Candidate list – especially when thinking further to the prioritisation process for Annex XIV.

Considering the long lifetime of PVC-products (profiles, wires, pipes, flooring etc.) and that the production of lead-free PVC started approximately only 10 years ago, we assume that the major part of volumes used for recycling (800 000 t/a planned for 2020) probably consist of lead-containing PVC. This will consequently lead to a slow dilution of lead in PVC since new lead-free PVC will emerge in the recycling cycle only in the future. Based on our current understanding of the authorisation process companies conducting recycling of lead containing PVC may be obliged to acquire an authorisation for their recycling use. If recycled PVC was subject to authorisation this would clearly contradict sustainability efforts. Similar considerations would also be relevant for lead battery recycling.

The German CA still favours to await the outcome of the self-commitment prior to the initiation of other REACh legislative routes.	Thank you for your comment. 

ECHA has received a request from the Commission in accordance with REACH Article 59(2) to prepare an Annex XV dossier proposing the identification of this substance as SVHC.

Preparation of a risk management options analysis (RMOA) before proposing the identification of a substance as SVHC is a voluntary step in the co-ordination of risk management activities among the Competent Authorities for REACH but not a requirement of REACH. 

Nevertheless, ECHA agrees on the importance of identifying the most appropriate route(s) for risk management and on the co-operation and co-ordination of the regulatory risk management activities between the authorities. 

The RMOA submitted by the German CA will be taken into consideration before further risk management activities for this substance, beyond identification as SVHC, are initiated.
	
3	2012/10/01	Trade union
European Trade Union Confederation
Belgium	ETUC supports the identification of this substance as SVHC. 	Thank you for providing your opinion.	
2	2012/09/25	National NGO
Danish Consumer Council
Denmark	The Danish Consumer Council (DCC) supports the inclusion of the substance in the candidate list. The DCC wants dangerous chemicals in consumer products to be banned or at least minimized to the lowest possible levels. The inclusion of this substance to the candidate list is a strong signal to producers that the use of this substance should in time be stopped, and substituted with a less dangerous one.	Thank you for providing your opinion.	

Specific comments on the justification
Number	Date	Submitted by (name, Organisation/
MSCA)	Comment	Response	
18	2012/10/18	Industry or trade association
Belgium	We recommend ECHA to prove the SVHC justification. Page 10 indicates that ECHA has not carried out further analysis of this information in the Annex XV dossier and based their justification for SVHC properties on Index number 082-001-00-6 in Regulation (EC) No 1272/2008, classified in Annex VI, part 3, Table 3.1 (list of harmonised classification and labelling of hazardous substances) as toxic for reproduction, Repr. 1A (H360D: “May damage the unborn child”). 
However, Index number 082-001-00-6 classifies “lead and lead compounds” without further evaluation of specific substance properties. According to the registration dossier, the substance is a ceramic substance with a melting point of > 500 °C, indicating negligible vapor pressure, and a water solubility of 2.2 mg/L (at 6.2 pH, however, this substance might have higher solubility with another pH). The NOAEL for reprotoxicity was 250 mg/L drinking water as a result of a study conducted with soluble lead acetate. There is a factor of more than 100 between the NOAEL of lead compounds and the solubility of the substance. Under the same conditions,a reprotoxicity test with the substance might have lead to no effects on reprotoxicity and no classification as reprotoxic as the low solubility would have prevented a positive result for this specific endpoint. This questions the classification of the substance as Repr. 1A  based on a general harmonized classification of lead compounds and a read across with the soluble substance lead acetate. The literature describes that excretion is the main route of lead compounds with low solubility as they are not metabolized in the body.  In addition, lead and lead compounds have a binding OEL (Occupational Exposure Level) in the EU indicating that a threshold exists for lead and lead compounds. Under these circumstances, ECHA will have to evaluate the registration dossier to clarify if the substance meets the SVHC criteria for classification as toxic for reproduction category 1. 	Thank you for your comment.

The substance is classified as Repr. 1A according to Annex VI, part 3, Table 3.1 of Regulation (EC) No 1272/2008. Consequently the substance fulfils the criteria of Article 57 (c) of the REACH Regulation and can be identified as a Substance of Very High Concern following the procedure set our in Art. 59 of the same regulation. 

As the above cited harmonised classification is applicable law at present, it will not be questioned or discussed in the context of the currently ongoing SVHC identification process.

Manufacturers, importers and downstream users who have new information which may lead to a change of the harmonised classification of a substance in Part 3 of Annex VI of Regulation (EC) No 1272/2008 may submit a revision proposal in accordance with the second subparagraph of Article 37(2) of Regulation 1272/2008 to the competent authority in one of the Member States in which the substance is placed on the market.

Please also consider response to comment #18 in the section “general comments on the SVHC proposal”.	
			See also:
Comment 18 attachment (20121016_FINAL_Position_REACH_Consultation.pdf).pdf		
12	2012/10/18	International organisation
ASD AeroSpace and Defence Industries Association of Europe
Belgium	None	-	
15	2012/10/17	Company
Robert Bosch GmbH
Germany	See Attachment	Thank you for your comment. Please refer to response to comment #18 in the section “general comments on the SVHC proposal”.	
			See also:
Comment 15 attachment (Bosch-Contribution-for-Stakeholder-for-ECHA-lead.pdf).pdf		
4	2012/10/11	Member State
Germany	The substance basic lead carbonate (CAS No. 1319-46-6) is a reaction mass of the two constituents trilead bis(carbonate) dihydroxide (CAS No. 1319-46-6) and lead carbonate (CAS No. 598-63-0). The first constituent has the same CAS-No. as the reaction mass. 
The purity of the reaction mass is stated to be 100 % w/w, whereas the purity of the first constituent is stated to be 70 % w/w. Please clarify.

No information about the physical properties is given in the report or in the technical dossier. In the report a link to the Chemical Substance Search on the ECHA website is given instead. It would be better to provide these data directly in the report (and the technical dossier), so that no further search in a database is necessary
	Thank you for your comment.

Please note that the Annex XV dossier does not include information on the quantitative composition of the substance as the available information provided in the registration dossier (identifying the substance as a multi-constituent substance) is regarded as not reliable and not in line with the naming convention under REACH and CLP. However the IUCLID file provides this information extracted from the registration dossier. Nevertheless the substance should be regarded as the mono-constituent substance 'Trilead bis(carbonate) dihydroxide'. 

The proposal for identifying the substance as SVHC is based on its harmonised classification in Annex VI of Regulation (EC) No 1272/2008 (CLP Regulation). The physical properties of the substance are in this particular case neither necessary to define the identity of the substance addressed in the dossier nor to demonstrate that it meets criteria set out in Article 57. 

If however information on the physical properties would be required to describe the substance identity or to conclude on its SVHC properties those data should be included in the Annex XV dossier.	

PART II: Comments and responses to comments on uses, exposures, alternatives and risks

Specific comments on use, exposure, alternatives and risks
Number	Date	Submitted by (name, Organisation/MSCA)	Comment	Response	
18	2012/10/18	Industry or trade association

Belgium	Uses and RMO: Several EU directives exist aiming on prohibition and substitution of lead compounds for the remaining main uses of the substance in the EU. ECHA might want to evaluate that sufficient Risk Management Options exist and that non-covered uses might better qualify for restriction under Annex XVII. The following is covered:
Automotive industry 2000/53/EC (ELV): Vehicles put on the market after 1 July 2003 do not contain lead and lead compounds other than authorized with time-limitation and a sunset date in Annex II. The Commission shall amend Annex II regularly and delete materials and components of vehicles if the use of lead compounds is avoidable (Amendment: 2011/37/EC). Review of Annex II by the Commission; experts review substitutes to phase out lead and lead compounds. The ELV Directive qualifies as existing specific Community legislation.
Electronic Industry 2011/65/EC (RoHS recast) / 2002/95/EC (RoHS) and Battery Industry (Batteries Directive 2006/66/EC) are covering lead compounds similarly to the ELV.
Alternatives: A comprehensive evaluation of alternatives is available for both ELV and RoHS (commissioned by the European Commission; provided by Öko-Institut e.V. and Fraunhofer Institute for Reliability and Microintegration IZM).
All findings are documented in publically available reports:
RoHS (p 14 ff): http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_IV/RoHS_final_report_May_2011_final.pdf
ELV (p 184ff): http://circa.europa.eu/Public/irc/env/elv_4/library?l=/reports/final_rohs_2010pdf/_EN_1.0_&a=d
Exposure and Risks: In addition, lead and lead compounds have a Binding Occupational Exposure Limit in Europe of 70μg/dl blood, 0.15mg/m3 and many of the listed substances have a low water solubility and low vapour pressure.	Thank you for your comment. Please refer to response to comment #18 in the section “General comments on the SVHC proposal”. 

12	2012/10/18	International organisation
ASD AeroSpace and Defence Industries Association of Europe
Belgium	There already is existing legislation in Member States relating to the control of lead and its compounds in the working environment. Making this lead compound a Candidate SVHC would not provide increased protection to workers, the environment or consumers, but would increase uncertainty and costs in the industries which use this compound in their business processes. 

This substance is used in the manufacture of primary explosives. The manufacturing processes are of necessity small scale (Batch sizes less than 10kg), and facilities have suitable extraction and waste collection systems to minimise exposure of lead compounds to workers or the environment. Because of the nature of the product, good housekeeping is essential to all aspects of the manufacturing process. Processing takes place in dedicated facilities, and in many cases these are undertaken by remote processing operations which provide workers with protection from both exposure and the dangers of explosion from the products being manufactured. 
	Thank you for your comment and  the information provided. 

The current proposal only concerns identifying the substance as a substance of very high concern (SVHC) in accordance with REACH Article 59(2). However, if the substance is identified as SVHC, information in relation to controls under other legislation, use, exposure, risks and alternatives will be taken account of at later stages of the authorisation process.

Even though information provided during public consultation is taken into account, we would like to stress that the registrations are the standard tool and route to communicate information on a substance and its uses to the authorities The registrations are the authorities’ principal source of information when assessing the need of further risk management for a substance or (some of) its uses. Therefore, it is of utmost importance that registrants keep the information provided in the registration dossiers up to date and adequately describing the current use and exposure situation, including the operational conditions and risk management measures in place.
If certain uses are not covered by the provided exposure scenarios, downstream users can either communicate this through supply chain communication (via their suppliers) to the registrants, who then need to update their registrations accordingly, or prepare their specific chemical safety report and submit a downstream user report to ECHA.	
14	2012/10/17	Industry or trade association
ELSA (ESPA)
Belgium	To our astonishment there has been no analysis of the information provided in the registration dossier of this substance concerning Use, Exposure and Alternatives  and Risks. ELSA is of the opinion that such information is of paramount importance for this substance and that it should thus be taken into account during the process of potential identification of this substance as an SVHC. Therefore we have inserted an attachment in Section IV of the commenting form, which highlights the key points which shall be considered. In this document we do also refer to the comments filed for this substance by ILA, The International Lead Association, and which contains additional, more detailed information on specific topics which we did not repeat in the present attachment.
Note that the comments inserted for this substance are also applicable to 7 other lead compounds (collectively denominated “lead-based stabilisers”) and have been inserted  under each of the individual substances.	Thank you for your comment. Please refer to responses to comment #14 and #18 in the section “general comments on the SVHC proposal”.	
			See also:
Comment 14 attachment (SVHC-Public-Consultation-Oct-2012_ELSA-comments_CAS-1319-46-6.pdf).pdf		
15	2012/10/17	Company
Robert Bosch GmbH
Germany	See Attachment	Thank you for your comment. Please refer to response to comment #18 in the section “general comments on the SVHC proposal”.	
			See also:
Comment 15 attachment (Bosch-Contribution-for-Stakeholder-for-ECHA-lead.pdf).pdf		

Attachments
Comment number	Public attachment	
6	
Comment 6 attachment (20121016_FINAL_Position_REACH_Consultation.pdf).pdf	
9	
Comment 9 attachment (Position_REACH_Consultation.pdf).pdf	
14	
Comment 14 attachment (SVHC-Public-Consultation-Oct-2012_ELSA-comments_CAS-1319-46-6.pdf).pdf	
15	
Comment 15 attachment (Bosch-Contribution-for-Stakeholder-for-ECHA-lead.pdf).pdf	
16	
Comment 16 attachment (Position_REACH_Consultation.pdf).pdf	
18	
Comment 18 attachment (20121016_FINAL_Position_REACH_Consultation.pdf).pdf