The way that companies in the EU notify poison centers of hazardous chemicals in products could change as soon as January 2020.
What does it mean for you?
Ever noticed a red diamond-shaped symbol on the pack of DIY, gardening and household cleaning products? This is a often referred to as a ‘pictogram’, and tells you about the hazardous nature of the product, including what to do if it comes into contact with skin.
These pictograms and the associated text are on the label because of a piece of EU legislation called the Classification, Labelling and Packaging of Substances and Mixtures, or CLP. This is designed to communicate the hazard posed by a product or substance.
Here are three examples of the nine commonly used hazard symbols found on product labels.
Hazardous chemicals and Products
Just like those cleaning or DIY products, most of the chemicals we use, whether in the home, in industry or by professionals, are products made up of mixtures of substances.
If the product is classified as hazardous then the company producing it must notify their national poisons centre. These are organizations staffed by experts in medical toxicology who provide advice on what to do in cases of accidental or deliberate chemical exposure.
Poison centers in each EU country keep a database of all the hazardous products notified to them so that, if someone has been exposed to a product, the poison center can give advice on what to do (the phone number should be on the label).
Until recently, the ways in which companies notify the poison centers has varied from country to country. For example, in the UK notification is by a simple e-mail, whereas in other countries the process is more complex.
Also, some countries charge a fee while others do not. For multinational companies that must notify in several countries this system is cumbersome and inefficient.
The agency that manages chemical regulation across the EU, ECHA, has been looking at this issue over the past couple of years and is introducing a more streamlined system.
Changes to Poison Center Notifications
In future, all product notifications will be in a standardized format know as a PCN, or Poison Center Notification.
Companies will have three notification options. They will be able to:
- Submit their data directly online via a secure portal
- Enter their data offline into a dossier that is then uploaded via the portal
- Allow the data to be extracted directly from internal systems such as SAP and the notification generated automatically, saving considerable time and resources.
Companies Will Need to Prepare
What is becoming clear is that much more comprehensive data will be required than has been required before.
For example, under the new system the full chemical composition of hazardous products must be disclosed, including solvents, emulsifiers, fillers and the like. Previously, it was enough to specify the hazardous ingredients.
Toxicology data and information will also be required on the packaging. So companies will have to carry out a lot of basic work to characterize all of their products even before they can go through the notification process.
A new feature on product labels is a 16-digit code called the Unique Formulation Identifier, or UFI, as in this example.
The code is unique to each product and will enable staff at poison centers to rapidly access the full database on the product’s hazards and give precise advice on treatment. This will be far more efficient than relying on a product name, which may be used on several different products, or searching for some other code on the label.
This example of a UFI code on a label is from a brochure produced by ECHA called The UFI and What it Means for Your Product Labels, which contains useful information.
Deadlines to report hazardous chemicals
If they have not already done so, companies will have to move quickly to start compiling the information required for these notifications.
For all new products and for any existing product that is being updated, such as with a new formulation or new packaging, the deadlines for submission are:
|Consumer products||By 01 January 2020 (currently under review)|
|Professional products||By 01 January 2021|
|Industrial products||By 01 January 2024|
How can Anthesis help?
Anthesis has a team of experts who are well-versed in the requirements of chemical regulations, having been involved in the implementation of the REACH regulation on behalf of international clients in recent years.
We have the knowledge and experience to understand your requirements and to collect the necessary data and make the notifications. Furthermore, through the Anthesis Compliance Suite, we can fully utilize the option of making an automated submission.
About the author
Chris Turner has over twenty years’ experience of regulation in the chemical industry, the last ten years working primarily on REACH and CLP. Chris supports clients covering a wide range of sectors and his recent work has focused on following the development of regulations relating to endocrine disruptors and advising clients on how these will impact on their products.
Contact: Chris Turner Chris.Turner@anthesisgroup.com