Harmonized reporting of hazardous mixtures
Monday, 27 March 2017
A new regulation is amending CLP regarding the reporting of hazardous mixtures to appointed bodies (known as ‘poison centres’). Janice Robinson, Director Product Regulations at CEPE, on deadlines and the main changes of the regulation for coatings manufacturers.
Last September the new Annex VIII to the CLP regulation was agreed on by the REACH Committee. What are the changes?
Janice Robinson: The new regulation, which is due to be published in February 2017, will replace existing national rules for reporting of hazardous mixtures. Poison centres throughout Europe will in the future receive notifications according to a standard EU dataset. This aims to raise the overall quality and availability of information on hazardous mixtures and thus support the tasks of poison centres in responding to emergencies. It will also enable EU-wide statistics on poisoning incidents for the first time, and support the identification of priorities for new risk management measures. A cost/benefit study for the European Commission in 2015 estimated total net savings of 550 million EUR per year from the harmonised system (not counting any healthcare savings from faster/more accurate response); the savings – or costs – for individual countries or companies will, however, vary widely depending on their situation, and initially there will be costs for all parties in implementing the new system.
When will the requirements become mandatory and what will be the main changes for coatings manufacturers?
Robinson: The first mandatory deadline will be 1 January 2020, for reporting of hazardous mixtures supplied to consumers. There are further phased deadlines for reporting mixtures intended for professional and industrial use, on 1 January 2021 and 2024 respectively (but existing notifications made under previous rules will remain valid until 1 January 2025 if they do not change). Coatings manufacturers will need to adapt their IT systems and internal procedures to generate the electronic (XML) submission files in time for the relevant deadline. The rules are different from those for labelling or safety data sheets, so additional processes will be needed. Manufacturers will also need to begin adding a UFI code on the label of all products that they place on the market which are classified as hazardous according to CLP.
The European Chemicals Agency (ECHA) is responsible for the tools and aims to have all the final versions available by 1 January 2019, including potentially a ‘one-stop’ notification portal on the ECHA website which would be a very welcome development for industry.
What is the Unique Formula Identifier (UFI) code?
Robinson: The UFI is a new 16-digit alphanumeric code which unambiguously links the product in the package to mixture composition information in the database of the appointed body/poison centre. This is intended to help poison centres retrieve the correct information quickly in an emergency and thus avoid delay in providing appropriate treatment advice. The UFI is created using a VAT number and a numeric formulation code: a UFI Generator tool is already available free of charge on the ECHA website. It will also be possible to integrate UFI creation into companies’ internal IT systems. The UFI is likely to change more frequently than the labelling of the product, so for many companies it will be necessary to add it to labels on the packaging line, which could entail additional investment.
The complete interview can be read in the March issue of the European Coatings Journal, which is also available in the European Coatings 360° database.