On the 25th and 26th of October 2021, we finally had the chance to be at an on-site conference again. After a year of virtual events, this was a much-welcomed change. The 13th annual conference on CLP Classification, Labelling, and Packaging organized by the Chem-Academy was a hybrid event. It gave the participants the flexibility to either be on-site in Bonn or participate virtually. Opesians David Köhler, Mark Pfister, and Inga Hämmerle were on-site, ready to meet new faces and catch up with the familiar ones. The focus of this conference was the updates and challenges of the CLP regulation. The presentations were conducted by a balanced mix of chemical industry experts, authorities, and other stakeholders. Here are some of the highlights.
The EU New Green Deal and Its Impact
Top of the agenda for the day was the EU New Green Deal. Sabine Hausmann, Head of Global EH&S at Fuchs Petrolub SE presented on the goals of the EU New Green Deal and how it will affect REACH and CLP regulation. In short, as the EU New Green Deal aims to move towards a toxic-free environment, developments in studies of endocrine disruptors and persistent, mobile, and toxic (PMT) substances indicate that more substances will have to be added to the substances of very high concern (SVHC) list. If these changes are not adopted into the CLP and the UN GHS at the same time, this could be an issue for the industry.
The discussion that ensued makes it clear that companies should add their feedback and actively participate in the public consultation of the European Commission on the revision of the EU CLP regulation that is open until the 15th of November 2021. This was further echoed in the following presentations by Nicolaj Heuer of the Bundesanstalt für Arbeitsschutz and Arbeitsmedizin (BAUA) and Simon Steinmeyer of Chemetall GmbH.
Positive Impacts of Introducing the UFI
After almost a year of the mandatory requirement of the unique formula identifier (UFI) that was introduced with the CLP Art. 45 Annex VIII, Dr. Herbert Desel of the German Bundesinstitut für Risikobewertung (BfR) shared some insights. With the UFI, consumers can quickly identify mixtures in poisoning cases. Feedback obtained from the national poison centres in Germany mentioned that consumers actively use the UFI to identify mixtures.
Another positive impact is the fact that there has been a considerable increase in product notifications received by the BfR. The ECHA Submission Portal optimized the technical possibilities for reporting products. At the same time, the BfR is now enhancing its IT systems to deliver data more efficiently to the national poison centres in Germany.
Swiss Introduction of UFI
Starting January 1st, 2022, Switzerland will also require a UFI for product notifications. David Köhler from opesus AG presented the data requirements for product notifications in Switzerland as outlined in the Swiss Chemicals Ordinance (ChemO). Data reported to the BAG is transmitted for use to the toxinfo Suisse and is also published in the Swiss Product Register for Chemicals (RPC).
For a detailed comparison of the data requirements between the Swiss BAG and the EU PCN, see here.
That’s just some of the highlights from the first day. The second day covered a range of topics from labeling, dangerous goods regulations, and classification of waste and disposal of dangerous substances. The conference was wrapped up with a presentation by Roman Gimmini from DAW SE that looked into how these regulatory changes affect product safety departments. To keep up with new regulations and regulatory updates, product safety teams need to be equipped with IT tools that support their work. These IT tools should help them work efficiently and features such as automation and flexibility support that.
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