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CLP Article 45 Workshop supported by VCI a huge success

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our very first event was a huge success! Focused on the topic of CLP Article 45 Poison Centre Notifications for SAP customers and supported by the German Chemical Industry Association (VCI), we had a great turnout of 93 attendees – more than double of what we expected when we started planning a year ago.

It means one of two things:

  1. There is nothing better to do in February in Germany or
  2. This is arguably the most significant compliance topic for the world’s leading producers and importers of hazardous products.

The opesus CLP Article 45 workshop, supported by VCI, was held in Frankfurt on 7th February this year. We kicked it off with a pre-event dinner. Between tapas and beverages, we had a great time catching up with customers, former colleagues, and even made a few new friends along the way.

In the opening presentation Alexander Wegener, CEO of opesus, reminded us of the important work that Poison Centres do – they protect health and save lives. Then Dr. Desel from the German Federal Institute for Risk Assessment (BfR) shared the interesting fact of almost 600 calls being made every day. Clearly this is something we cannot take lightly – the advice that Poison Centres give is dependent on the quality of chemical information they have.

Daniel Sompolski from the ECHA Poison Centres Team took us through the requirements of CLP Annex VIII, clarifying which deadlines have to be met by whom. A requirement where a lot of misunderstandings happen; the first deadline of 1st of January 2020 for consumer use applies even if you don’t directly sell to end consumers. The deadline is also relevant for all companies that have products that end up in a consumer use several steps down the supply chain.

Finding solutions was the theme of the workshop; and Ralf Coenning from SAP talked about SAP S/4HANA for Product Compliance. He also gave an overview on how opesus’ software complements SAP EH&S to provide companies with a comprehensive set of tools to fulfill the requirements of CLP Article 45. Marvin Bahnsen, consultant at opesus, highlighted the software features of opesus EHS Product Notification and presented the timelines of ECHA, SAP, and opesus product development.

After a tasty lunch, two of our pilot customers – Dr. Spanke from BASF and Mr. Steiger from Biesterfeld – shared the challenges and recommendations for companies taking steps to ensure compliance with the CLP Article 45 requirements.

In the final presentation our product manager Markus Pogrzeba offered a detailed look at our findings from over 50 customer workshops. A lot of notes were taken as he pointed out best practices gathered from his extensive experience in consulting at chemical companies (of all sizes and within the complete supply chain).

With all that information presented and discussed, the hours just flew by. We again want to thank all those who have contributed to the great outcome of our workshop by giving presentations, asking questions or just being there. If you are interested in learning  how opesus can help your company comply with the requirements of CLP Article 45, contact us or check out our opesus EHS Product Notification.

CLP Article 45 Workshop for SAP Customers supported by VCI

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With the support of the German Chemical Industry Association (VCI), opesus AG offers a workshop on CLP Article 45 (Poison Centre Notifications, PCN) for SAP customers.

Date and Time

Workshop

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Date and Time: 7th of February 2019, 9:30 – 16:30

Location:

Lindner Hotel & Sports Academy Frankfurt

Otto-Fleck-Schneise 8

60528 Frankfurt/Main

Germany

Optional Evening Event: Pre-workshop social

Date and Time: 6th of February 2019, 6 pm

Location: In the conference hotel

Dresscode: Casual or Smart Casual

Overview

This event is targeted toward SAP customers and specifically VCI members that are obliged to submit notifications according to CLP Article 45 (Poison Centre Notifications – PCN). They will get practical advice on how to deal with the challenges ahead:

  • Get advice and best practice tips from industry leaders and SAP experts to meet your regulatory requirements
  • Collaborate and learn more about your obligations as well as available guidelines and tools
  • Benefit from our experience with ongoing pilot implementations and the ECHA pilot project for the PCN format 
  • Get ready for the first submission deadline on the 1st of January 2020 for mixtures intended for consumer uses

To learn more about the regulation, visit ECHA at https://poisoncentres.echa.europa.eu/de/information

We expect around 60 participants.

The conference language is English.

Topics

  • Regulatory requirements of CLP Article 45
  • Guidelines, tools, and expectations from ECHA
  • Software from SAP and opesus
  • Industry challenges and best practices

Speakers

  • Authorities
    • European Chemicals Agency (ECHA)
    • Bundesinstitut für Risikobewertung (BfR)
  • Industry
    • BASF
    • Biesterfeld
  • IT experts
    • SAP
    • opesus

Agenda

TimeSpeakerOrganizationTitle
09:00WELCOME COFFEE
09:30Alexander WegeneropesusGreetings and opening
09:50Daniel SompolskiECHAPoison Centres Notifications as of 2020
10:35Dr. Herbert DeselBfRNational implementation of CLP Article 45 in Germany
11:10BREAK
11:30Ralf CoenningSAPSAP and CLP Article 45. Now and with S/4HANA.
12:05Marvin BahnsenopesusStatus and timeline for opesus EPN
12:25BREAK
13:25Michael SteigerBiesterfeldChallenges of Poison Centre Notifications from a chemical distributors point of view
14:00Dr. Jörg SpankeBASFChallenges and recommendations from a chemical producer
14:35BREAK
14:55Markus PogrzebaopesusBest practices and recommendations for implementing CLP Article 45
15:40PanelPanelPanel discussion
16:20Alexander WegeneropesusSummary and farewell
16:30END

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Event Information

Fee

The registration fee is 390 €.

Accommodation

Several rooms have been reserved from the 6th to the 7th of February 2019. The rate is 119,- € and includes breakfast and VAT. You can make the reservation during registration. Or you can contact us under pcnworkshop@opesus.com You can pay for the room directly in the hotel.

About opesus

Since 2013, we at opesus have been dealing with product notifications to poison centres. Our opesus EHS Product Notification is the market leading solution for SAP EHS customers to submit such notifications.

opesus:

  • Is an active participant in the ECHA IT User Group for CLP Article 45. An overview of all participants can be found on the ECHA website.
  • Participates together and on behalf of the VCI in the ECHA pilot project for the PCN format.
  • Works with the national authorities.
  • Is represented in various SAP EHS user groups, particulary the VCI group for SAP EHS.
  • Coordinates regularly with product management and development teams of SAP.

Registration

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ChemCon Europe 2018 in Budapest

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ChemCon Europe 2018 will happen from November 12th to 16th in Budapest.  One of the seminars will focus on Poison Centre Notifications according to CLP Art. 45. The seminar features several speakers, among them from ECHA (Mercedes Viñas, Daniel Sompolski), BASF and the Dutch Poison Information Centre. Alexander Wegener from opesus gives a lecture on “How to track portfolio changes or raw material changes in relation to updating of your poison centre notification?”.

If you are visiting ChemCon, we would be happy to talk to you at our booth. We are looking forward to learn new things, meet people and to have interesting discussions there!

CLP conference and workshop of Chem-Academy 2018 in Bonn

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On 22nd and 23rd of October 2018 the CLP conference of the Chem-Academy will take place. One of the main topics there will be “Art. 45 of the CLP Regulation: regulatory requirements and technical implementation “. Alexander Wegener from opesus gives a lecture on “Technical Implementation of Art. 45 CLP-VO”.
Daniel Sompolski from ECHA and Dr. Herbert Desel from the Federal Institute for Risk Assessment (BfR) will talk about the legal obligations.

Then, on October 24, Chem-Academy organizes a full-day workshop on “Implementing Technical Solutions to Implement Art. 45 CLP Regulation”. This workshop will be led by Markus Pogrzeba and Alexander Wegener, both of opesus.

We are looking forward to the event and many interesting questions and discussions there!

Implications of PCN-Format of CLP Article 45 for Product Notifications

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The European Chemicals Agency (ECHA) has published the technical format for reports to poison centres (according to CLP Article 45)! The new PCN-Format is based on the internationally harmonised IUCLID format. This article explores the effects the new format will have on industry.

IUCLID format for product notifications

Contrary to the preliminary draft, the new PCN-Format is now based on the IUCLID format. The IUCLID software allows data on chemical properties to be maintained, stored and exchanged. The internationally harmonised IUCLID format is used for this purpose. This format will now also be used for notifications to poison centres in accordance with CLP Article 45.

The IUCLID format consists of a variety of templates for documents, which are structured according to the type of information it contains (e.g. GHS data).

For the PCN format, 15 existing documents are reused. In addition, two new templates are added to the IUCLID format: “Product Information” and “Dossier Header”, which provides notification type details (e.g. update). All completed documents are combined into a dossier, which associates the contained documents through administrative data. The completed dossier will subsequently be sent to the national authorities. The dossier can then be used by national poison centres for emergency calls.

Effects of the PCN-Format for the industry

At opesus, we work in close cooperation with industry, ECHA and SAP to assist companies with their CLP Article 45. We are currently developing a new version of our software opesus EHS Product Notification, which supports the new PCN-Format. Based on our experience, we see the following effects of the new format:

Increased Complexity

A dossier consists of many documents that are linked by administrative data. The new PCN-Format is therefore very complex and much more comprehensive compared to previous formats.

For example, a very simple notification (a few substances with no “special” types) generates about 1,500 lines of XML code in PCN-Format. In comparison, the notification of the same mixture in the previous German (BfR) format consists of about 150 lines of XML code.

Possible use of IUCLID software

One way to create IUCLID-compatible dossiers is to use the IUCLID software. The software is available for free. However, the data must be maintained manually via the input mask of the software. For this reason, in our opinion the use of IUCLID software is advisable only for smaller companies with very limited mixtures subject to notification.

Note: In the past, SAP EH&S had an IUCLID interface. However, the interface currently only supports the older IUCLID 5.4 version and will be discontinued in SAP S/4HANA. From our point of view therefore, the IUCLID interface in SAP EH&S is not a viable solution.

Annual IUCLID updates

The IUCLID format is subject to annual updates. These updates can be prompted by changes in legislation or to the PCN-format. Also, changes that do not originate from CLP Art. 45 need to be evaluated and may cause adaptions to PCN notifications. For all solutions that creates notifications in PCN-Format, availability of software maintenance is therefore essential to be able to react to changes in time and reliably. We recommend maintenance for all our customers for our opesus EHS Product Notification software.

New version of the free opesus UFI generator available

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We have released a new version of the opesus UFI Generator for SAP EHSM customers. With the new version, Unique Form Identifiers (UFI) can be generated and stored automatically in SAP EHSM.

Unique Formula Identifier (UFI)

As part of product notifications according to CLP Article 45, the UFI will gradually become mandatory from 2020 onwards. The UFI is a unique code generated by the manufacturer or importer. The UFI must be included in the notifications to the Poisons Centres and in the safety data sheet. Additionally, it must be printed on the label.

More information about the UFI can be found on the ECHA website.

New SAP property “Poison Centers Notification (EU)”

On May 18th, SAP released the new standard property called “Poison Centers Notification (EU)”. This property can be used to store the UFI. When using the new standard property, the UFI is thus stored on specification level.

Advantages of the opesus UFI Generator

The opesus UFI Generator contains a ruleset that generates valid UFIs and writes it into the new SAP property. Therefore, the process of data maintenance of UFIs can be largely automated.

All steps are carried out directly within SAP EHSM. There are no other web services to connect.

The ruleset can be configured by various parameters. You can tailor the process for creating UFIs accordingly to customer-specific needs – e.g. by using another property for storage.

How to get the opesus UFI Generator

The opesus UFI Generator is available to all SAP EHSM customers for free under the MIT license. You can request the UFI Generator via the contact form on this page. We will then send you the documentation and the software.