There are two options for submitting information about industrial mixtures:
Posted: Tue Dec 17, 2024 6:10 am
As the New Year approaches, the January 1, 2024 deadline for submitting poison center information in the new CLP Annex VIII format for industrial mixtures may seem a long way off, but it is a good time for organizations to ensure they have plans in place to meet the deadline.
A product is considered an industrial mixture if it is used only in industrial applications. If a mixture is formulated into another mixture for professional or consumer uses, even if this occurs several steps down the supply chain, it must be notified as a professional mixture or a consumer mixture as appropriate—the deadline for which is 1 January 2021.
Full submission
Limited submission, provided that additional product information can be provided investor database quickly in the event of a health emergency
The limited submission option allows companies to provide only the information on the composition of the mixture that would normally be included in a Safety Data Sheet, allowing them to better protect their confidential information. However, to benefit from this option, companies must be able to provide additional information quickly by telephone or email if requested in the event of a health emergency. This service must be available 24/7, and the company must be able to provide the information in the language of the Member State where the mixture is placed on the market, unless the Member State has provided otherwise (see here for a list of countries and languages they accept).
The CLP regulation does not define what is meant by rapid access to additional information, but regulators might be expected to take into account other standards for the provision of emergency information in a chemical incident when deciding what might be considered reasonable. For example, the CEFIC ICE scheme, which sets standards for responding to transport incidents, requires callers to be connected to an emergency response expert (including an interpreter if necessary) within 3-5 minutes, initial advice to be provided within 10 minutes, and further detailed follow-up, if necessary, within 30 minutes.
If companies are unable to provide an appropriate emergency number and response themselves, they may provide full notification to the poison center, or contract additional rapid advisory services to appropriate organizations such as CHEMTREC who have 24/7 access to local telephone numbers, interpretation services, and medical professionals who can handle the call or provide support to the relevant Poison Center.
A product is considered an industrial mixture if it is used only in industrial applications. If a mixture is formulated into another mixture for professional or consumer uses, even if this occurs several steps down the supply chain, it must be notified as a professional mixture or a consumer mixture as appropriate—the deadline for which is 1 January 2021.
Full submission
Limited submission, provided that additional product information can be provided investor database quickly in the event of a health emergency
The limited submission option allows companies to provide only the information on the composition of the mixture that would normally be included in a Safety Data Sheet, allowing them to better protect their confidential information. However, to benefit from this option, companies must be able to provide additional information quickly by telephone or email if requested in the event of a health emergency. This service must be available 24/7, and the company must be able to provide the information in the language of the Member State where the mixture is placed on the market, unless the Member State has provided otherwise (see here for a list of countries and languages they accept).
The CLP regulation does not define what is meant by rapid access to additional information, but regulators might be expected to take into account other standards for the provision of emergency information in a chemical incident when deciding what might be considered reasonable. For example, the CEFIC ICE scheme, which sets standards for responding to transport incidents, requires callers to be connected to an emergency response expert (including an interpreter if necessary) within 3-5 minutes, initial advice to be provided within 10 minutes, and further detailed follow-up, if necessary, within 30 minutes.
If companies are unable to provide an appropriate emergency number and response themselves, they may provide full notification to the poison center, or contract additional rapid advisory services to appropriate organizations such as CHEMTREC who have 24/7 access to local telephone numbers, interpretation services, and medical professionals who can handle the call or provide support to the relevant Poison Center.