Compass to chemical safety

Professional articles, useful background information and analyses on chemical safety

Our goal is to provide up-to-date information to professionals working in the field of chemical safety, as well as to companies affected by regulations. For these purpose, we continuously broaden and update the contents of our website.

The right direction to chemical safety…

 

Professional articles, analyses

 

Useful information for the harmonized submission of mixtures (PCN)

The unified, harmonized notification of mixtures with a unique formula identifier (UFI) specified in Commission Regulation (EU) no. 2017/542 (PCN submission) provides an opportunity in all EEC Member States to rapidly report information regarding the mixture during an emergency health response situation.

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Unique formula identifier. Information concerning the application of the UFI

The unique formula identifier (UFI) is a 16-character code to be indicated on the label of mixtures. The UFI is an element of the submission of hazardous mixtures which has to be carried out in a harmonized form (PCN).

As a result of the submission, unified data will be available in the EU member states for medical personnel. The application of the code makes it possible for Poison Centres to provide information about the hazardous mixture during emergency situations.

Provisions regarding the application of the UFI as well as the labelling of mixtures have been announced in Commission Regulation (EU) 2017/542 which amends Regulation (EC) 1272/2008 (CLP) by adding a new Annex (VIII) to it. These provisions will be mandatory for all member states of the EEA.

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Easily about safety data sheets

The document attached to chemical products is only regarded as “safety data sheet”, if, at the date of delivery, it meets the content and format elements of the currently valid and relevant regulations.

Our safety data sheet sample was created and made public in accordance with the valid regulations. The safety data sheet sample can help to check the supplier’s safety data sheet on a basic level, but for the judgement of content accuracy, deeper professional and regulatory knowledge is needed.

What we definitely have to check in safety data sheets

Before talking about the main aspects of checking the received safety data sheet, please, read our article about the conditions under which a safety data sheet must be supplied.

First step:

We can (and we need to) check the language of the received safety data sheet. It may be sound strange but in certain cases, the supplier of the chemical product cannot be obligated to supply the safety data sheet in our language.

At the same time, those companies who have a safety data sheet translation software, are likely to give out safety data sheets in the language of the client, even if according to the regulations it is not their task. Safety data sheets made by a software require special caution since they are highly questionable in a professional point of view. On the other hand, sometimes literal translation by human resources cannot guarantee appropriate result either. During the creation and translation of safety data sheets only a small part of the working process  can be regarded as a traditional translation task; it is necessary in all cases to take into account the national regulations and to check the content (e.g. classification) of the data sheet.

Second step:

We need to check the “validity” or with everyday expression the expiration date of the safety data sheet. In professional point of view, we can state that there is no such term as “expiration date” but we certainly have to admit that there are rules regarding the revision of the safety data sheet.

Further steps:

Further steps to check the adequacy of the safety data sheet will be largely determined by the activity of the company and the “nature” of the substances and mixtures used. As a distributor, if we buy products from domestic sources, by receiving inadequate data sheet we risk that our clients will not buy the product with such a document and we will suffer market loss.

If we buy chemical products in EEA countries, we may have other tasks as a “distributor” at the site of distribution. Such task can be the notification (the currently different regulation will be standardized by the PCN notification) and labelling, which cannot be done correctly by using an inadequate data sheet.

Downstream users have probably the most tasks with the received data sheets. Please read our summary about useful background information for downstream users on safety data sheets.

We would like to note that downstream users have to check the content of the supplied safety data sheet too, which can be requested by the authorities during on-the-spot checks.

Practical advice to CLP label creation

As a distributor – if we have an adequate safety data sheet – labelling obligation can be fulfilled relatively easily according to section 2.2 of the safety data sheet.

As a manufacturer, a mixture creator downstream user or an importer we have to know the provisions in detail since the creation of the safety data sheet is also the task of the company.

Minimally knowing the following information is necessary to create the label draft of our product:

 

Obligatory section for supplemental information

At the creation of a CLP label, most mistakes are probably done in this section. Due to the components and special properties of the product, practically the content criteria can only be fulfilled by literally following the provisions Article 25 of Regulation (EC) No 1272/2008.

It is important to note that the seemingly constant hazard (H-statements) or precautionary (P-statements) statements can also change. Always use the relevant and official statements!

What importers usually forget…

Yes, it is the notification obligation to the CLP classification and labelling inventory.

This obligation is not related to the usual REACH registration of import volumes – maybe this is the reason for paying less attention to it.

All imported substances (pure substances), as well as substances that are classified as hazardous under CLP and present in a mixture, which results in the classification of the mixture as hazardous must be notified.

Before starting an import activity, we recommend reading our article about REACH obligations  of manufacturers and importers.

Dumping of Chinese goods and the chemical safety

Yes, the provisions of chemical safety are also applicable to chemicals substances that are imported in the form of articles.

In the case of articles, the most important obligations are related to the communication and authorization of SVHC substances, but in certain (rare) cases we could have a REACH registration obligation as well.

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