I think the draft has made a good fundament for structuring and organizing the information needed for a risk management system. This is well put into place, especially with the life-cycle as a central tenet in the system. The strong information driven process is problematic though. I fear that such a process is too statice, or linear, and spends too many resources on generating information about present hazards, in comparison to searching for, and generating information related to safer alternatives which include input substitution, final product reformation, and/or process changes. This should be conducted in parrallel.
Thank you for providing this interesting draft version.
Åsgeir Helland
Technology and Society Lab
Innovation and Technology Analysis Unit
Swiss Federal Laboratories for Materials Testing and Research (EMPA)