Can "Hazard-Cost-Effectiveness Analysis" improve the risk management of chemicals under REACH?

Cost-Effectiveness Analysis (CEA) is a decision-making framework to prioritize policy decisions for chemicals. Differences in hazard profiles among chemicals are not integrated in CEA under the EU REACH Regulation, which could limit its relevance. Another concern is that two different economic decision support methods (CEA for chemicals considered as PBTs or vPvBs from a regulatory perspective and Cost Benefit Analysis (CBA) for others) are used under REACH. To address this situation, we define "Hazard" CEA by integrating a hazard score, based on persistence, bioaccumulation and (eco)toxicity, in the effect indicator of CEA. We test different designs and parameterizations of Hazard-CEA on a set of past socio-economic assessments under REACH for PBT and non-PBT chemicals. Weighing and thresholds in hazard scores do not have a significant impact on the outcome of Hazard-CEA but the design of the hazard scoring method does. We suggest using an integrated and unweighted scoring method with a multiplicative formulation based on the notion of risk. Hazard-CEA could be used for both PBT and non-PBT chemicals, to use a single method in REACH and therefore improve consistency in policy decisions. Our work also suggests that using Hazard-CEA could help make decision easier.