E: This group of substances has properties that give rise to concern besides the criteria for identification as “hazardous” e. g. according to CLP and should be used with caution. Once released to the environment they can pose a risk to the environment or human health even without having any yet identified adverse effects on the environment or on human health via the environment.
Beyond that , persistent pollutants may enrich in the environment and may
distributed over long distances. Any pollution of the environment has to be prevented in any case.
Make sure that the amount of substance does not lead to PEC / PNEC > 1. Take into account that
the substance might be used in different products / mixtures or processes.
Further measures are necessary:
• For operators:
substitution, release minimisation up to prevention of emission, safe handling, check if substance belongs to substance group of concern, e.g. PFAS, check information on ECHA website for assessment of chemicals universe
• For branch associations:
give advice to installation operators, conduct research for substitution, …
• For TWG:
derive BATs for BREFs, make sure that actual state of knowledge is reflected in BREFs at any time