With speakers from national authorities, poison centres as well as industry and IT, the two-day program covered a wide variety of topics. This allowed the participants to get a deeper understanding of regulatory requirements as well as challenges and recommendations when implementing these requirements.
A Great Platform for Exchange of Knowledge
With working sessions and room for discussions between the presentations, the workshop provided not only a great platform to gather knowledge about CLP Art. 45 but also for exchange between different stakeholders. We already had the pleasure to lead last year’s, CLP Art. 45 Workshop and especially loved the lively discussions that evolved between the participants. At first, we were a bit uncertain how the interaction would work in this year’s web conference without real live face-to-face communication. We were quickly impressed by how well it worked and how much the participants contributed.
Challenging: Point of Sales Formulations
The workability study and the changes proposed in the Second Amendment to CLP Annex VIII provided a foundation for exchange in particular. From an industry and distributor perspective, especially the Point of Sales (PoS) Formulation is still challenging and have to be added to the bespoke paint. The current draft requires that UFIs of hazardous pastes/tinters with a concentration of over 5% must be included in the supplemental information on the label together with their concentration. This information would need to be printed at the PoS. Examples that were discussed described that 5 UFIs would have to be added to the bespoke paint. Updating the UFIs for mixtures that contain up to 36 pastes is a further challenge. The topic will be further discussed between authorities, paint producers, and distributors.
Project Planning and Implementation
In addition to the latest regulatory information, the participants also learned about project planning and further details when implementing Poison Centres Notification requirements.
Not only technical details such as the PCN format generation or connection of industry IT system to the ECHA Submission Portal via S-2-S-connection must be considered to establish a successful notification process. From a business perspective, also topics such as protection of confidential business information (CBI) via smart UFI assignment as well as the randomization of the full composition are highly relevant. As mixtures must be notified before placing on the market, supply chain management is also an important topic for industry and distributors. To ensure compliance, avoid penalties, and protect CBI it is recommended to establish contractual agreements with suppliers and customers.
We loved the energy during the workshop and like to thank everybody for their contribution. It was great to see how well a web conference can turn out.