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Päivi Jokiniemi and Paul Trouth
Article related to: CLP
Poison centres: changes to placing hazardous mixtures on the market
If you or someone you know has ever been accidentally exposed to a chemical product, you can pick up the phone and call a poison centre to ask for medical advice. The first question they may ask you is: what exactly is in the product? We look at why answering this question might become a lot easier in the future.
Poison centres help to ensure the safe use of chemicals and offer preventive and remedial measures if somebody has been exposed to a poisoning agent. They give medical advice to general consumers and physicians on health emergencies arising from exposure to hazardous chemicals or to other toxic agents. They also provide an assessment of whether a particular exposure is hazardous, and give information on whether treatment is needed, and if so, what kind.
A new character code for product labels
While you may know the brand name of the product, it is not always straightforward for poison centres to give you the best possible medical advice based on this information alone, as the product labels currently only provide limited information.
To improve this situation, a new 16-digit character code known as a unique formula identifier (UFI) will be required on the labels of products containing hazardous mixtures from 1 January 2020.
The aim is to help poison centres identify the exact poisoning agent so a more immediate health response can be given if someone is poisoned. Placing the UFI on the labels of your products is already possible, but it will only be mandatory from 1 January 2020.
The UFI provides a link between the product placed on the market and the information on the composition that companies have to make available to poison centres, such as the trade name of the product, its colour, packaging, product category and toxicological information.
Who has to submit information?
Before placing mixtures on the market, importers and downstream users must submit information on the mixtures classified for any health or physical hazard to the body appointed to receive this information in each Member State.
The information has to be provided to Member State appointed bodies and poison centres so that consumers, physicians and other professional users can contact them and get the best possible advice for medical treatment.
Other operators that rebrand or repackage mixtures may also need to make such notifications.
What are the notification deadlines?
Currently, national requirements on notifying hazardous mixtures vary between Member States. The introduction of Annex VIII to CLP harmonises the information requirements relating to emergency health response and preventative measures across the EU.
The new obligations for notifying hazardous mixtures before placing them on the market, such as adding the UFI on the label, submitting the full chemical composition (including the non-hazardous components) and assigning a product category from a harmonised product categorisation system, have different deadlines depending on the use.
The phased deadlines are by 1 January:
- 2020 for consumer uses;
- 2021 for professional uses;
- 2024 for industrial uses only.
Mixtures that were already on the market when this obligation started being imposed will need to be re-notified by the end of the transition period, on 1 January 2025.
By 2025, all relevant products on the market are expected to be notified and have the UFI on their labels.
Make sure you know your supply chain – it might affect the deadline obligation for your mixture. In cases where an industrial mixture is eventually included in a mixture for a consumer product, you will need to meet the earlier deadline of 2020.
|The deadlines to notify hazardous substances are on 1 January in 2020 for consumers uses, 2021 for professional uses, and 2024 for industrial uses only. 1 January 2025 marks the end of the transition period. Image: ECHA.|
How to notify
ECHA will provide the harmonised format necessary for the notifications. The Agency has also started to develop a poison centre notification (PCN) portal that will enable companies to submit the information centrally, and dispatch the notifications to the appointed bodies and poison centres of the (relevant) Member States where the product is placed on the market.
There are other tools available or under development that will help industry prepare and submit their notifications.
The UFI Generator has been finalised, so companies can already start using it to generate their UFIs and prepare internally before the first deadline on 1 January 2020.
A developers' manual is also available for companies that prefer to develop their own UFI generator and integrate it in their IT systems.
The poison centres notification (PCN) format that defines the data requirements and structure for the submission of information to the appointed bodies and the related editor are currently being developed, as well as a harmonised product categorisation system (EuPCS) that details the different product categories based on their main intended use.
These tools will be available on ECHA's website in early 2018.
Why a central notification portal?
There are a number of benefits for industry and Member States in developing a central notification portal.
For industry, the portal will limit the administrative burden and reduce the costs of submitting information by decreasing interactions with Member State appointed bodies. It will also secure confidential business information through the supply chain by reducing the number of channels of data transmission, reduce the number of errors by offering validation tools and support multilingualism by allowing companies to submit in their own language while ensuring that information to the appointed bodies is in their language.
For Member States, the central notification portal will reduce the need for IT development in each Member State thereby reducing the overall costs.
A central portal also offers the possibility to work as an information hub for cases where mixtures are notified in one Member State but marketed in a different Member State as part of another mixture.
The scope of this central notification portal and the functionalities that it may offer to both industry and Member States are still under discussion. A first version with some basic options is expected to be available in 2019.
What you need to notify
Companies will need to notify product information such as:
Text by Jakob Aahauge
Published on: 15 February 2018
Top image: © IStock.com/BahadirTanriover
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18-22 March (tentative)
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