Attention to Substances of Very High Concern (SVHC) is increasing. That is hardly surprising. Pressure on water quality is growing, regulations are becoming stricter, and regulators increasingly expect companies to demonstrate how they prevent and reduce emissions of hazardous substances.
Yet many organizations still view an Avoidance and Reduction Program (ARP) primarily as a permitting requirement. That is a missed opportunity. A well-designed ARP is not just a report for regulators; it is a practical tool for gaining control over risks, compliance, and future business operations.
What Are Substances of Very High Concern?
Substances of Very High Concern (SVHC) are substances that can pose serious risks to both human health and the environment. Examples include substances that are carcinogenic, may affect reproduction, or accumulate in ecosystems and the food chain.
The most well-known group today is PFAS, but the list is much broader and is regularly updated by the Dutch National Institute for Public Health and the Environment (RIVM). Increasing attention is also being paid to potential Substances of Very High Concern (pSVHC), substances that have not yet been formally classified as SVHC but are suspected of presenting similar risks.
Dutch SVHC policy is based on a clear principle: emissions should be prevented wherever possible and minimized where prevention is not feasible.
From Source Control to Continuous Improvement
The Dutch SVHC policy is built on three key pillars:
- Source control
- Minimization
- Continuous improvement
Priority is always given to source control. Can a hazardous substance be replaced with a less harmful alternative? Can a process be modified to reduce the use of SVHC? These are the first questions that should be addressed.
When complete substitution is not possible, the focus shifts to minimization. This may involve process optimization, enhanced control measures, or additional treatment technologies.
However, the third step is often underestimated: continuous improvement. Organizations are expected to periodically assess new opportunities for further emission reductions. The ARP serves as the guiding framework for this ongoing process.
Why Water Is Receiving Increased Attention
Historically, many companies focused primarily on air emissions. Water emissions often received less attention. That is changing rapidly.
Growing concern about PFAS, pharmaceutical residues, drinking water protection, and the objectives of the European Water Framework Directive (WFD) is placing greater scrutiny on discharges to water bodies. Regulators increasingly expect a substantiated approach demonstrating which SVHC are present, where they originate, and what measures are being taken to limit emissions.
For many companies, this means existing permits and compliance obligations need to be reassessed.
An Effective ARP Starts with Insight
In practice, many SVHC-related challenges can be traced back to a single question: Do we really know which substances are present and where they come from? An effective Avoidance and Reduction Program therefore begins not with technology, but with insight.
This includes:
- Inventorying raw materials, auxiliary materials, and additives;
- Analyzing production processes;
- Understanding wastewater emission pathways;
- Evaluating existing control measures;
- Monitoring relevant SVHC in influent and effluent streams.
This phase often provides valuable and sometimes unexpected insights. Organizations frequently discover that certain substances are not being monitored, that emission sources are not fully understood, or that existing measures are already delivering more impact than originally assumed.
The Biggest Challenges in Practice
While the objective is clear, implementation is often complex. Companies commonly face challenges such as:
- Suppliers do not always provide complete information about substance compositions.
- The source of specific substances, such as PFAS, can be difficult to identify.
- The effectiveness of existing wastewater treatment systems is not always fully understood.
- Alternative substances or technologies may be technically feasible but difficult to implement economically or operationally.
- Balancing technical feasibility, operational reliability, environmental benefits, and costs requires specialized expertise.
As a result, an ARP is rarely just an administrative exercise. It requires collaboration between operations, production teams, environmental specialists, suppliers, and regulatory authorities.
Turn Compliance into Continuous Improvement
Organizations that successfully manage SVHC do not treat the ARP as a document that is updated once every five years. Instead, they integrate SVHC management into their existing continuous improvement processes.
By incorporating SVHC challenges into the familiar Plan-Do-Check-Act (PDCA) cycle, organizations create a system in which monitoring, evaluation, and optimization occur continuously. New insights, regulatory developments, and technological innovations can therefore be translated more quickly into concrete actions.
This not only improves preparedness for regulatory inspections and permitting processes but also provides a stronger foundation for future investment decisions.
Don’t Wait Until the Deadline
Experience shows that companies that begin working on their ARP shortly before a compliance deadline often run out of time to develop sufficient insight and substantiate meaningful reduction measures.
With topics such as PFAS, water quality, and SVHCs moving steadily higher on the agenda, now is the time to take a critical look at existing processes, monitoring programs, and emissions.
Not because it is required, but because a robust Avoidance and Reduction Program ultimately delivers far more than compliance alone. It helps organizations manage risk, support sustainable operations, and remain resilient in an increasingly demanding environmental and regulatory landscape.