With around 60% of the Forum subscribers being CHCS members who are themselves mostly UK based, there is a natural bias towards UK and European issues. But with the gradual introduction of GHS, and the magnitude of international trade, especially in mixtures, there are many product stewards outside the UK who consider it worthwhile to subscribe. At the last count, that included more than a quarter of the subscribers, located in over twenty countries.

The CHCS email Forum generates significant interest, and is known to have a number of readers working for various regulatory bodies. Subscribers have often been able to find help and guidance in areas where the regulatory framework is silent or unclear.

The Forum is easy to join, free, and open to anyone anywhere in the world who has a professional interest in the subject.

The Forum is not a bulletin board, but a 'push' email system. Forum Subscribers submit their contributions by email to the Forum Operator: Questions, Responses, and News items. The only restriction in scope is that submissions should be be relevant to Chemical Hazard Communication (CHC) matters.

The Forum Operator ("ForOp"), who also acts on behalf of CHCS as the primary moderator, then emails the content to each person on the subscription list. The subscription list is securely retained, and the addresses of other subscribers are not present in the emails received by the subscribers.

On receipt of a Forum message, subscribers can:

• discard it, as being of no interest
• note it, and retain it for information
• answer, completely or partially, a question that has been posed
• submit a relevant comment on any item
• forward the message to anyone else

Examples of recent Questions from the Forum with the various answers that reply directly and also draw out the different points involved are as follows:

QUESTION 1

If a chemical is classified under DSD as N; R50/53, do you need to show both H400 and H410 or can you use H410 alone?
Having both just duplicates the acute hazard statement.
i.e.:
H400 - Very toxic to aquatic life.
H410 - Very toxic to aquatic life with long lasting effects.

ANSWER 1

CLP Article 27 (Principles of precedence for hazard statement) would permit omission of H400 on the label on the grounds of "evident duplication or redundancy".

However the specific case has now been addressed by way of the Second ATP to CLP where this text is added to the beginning of Annex III:
"(a) if the hazard statement H410 “Very toxic to aquatic life with long lasting effects” is assigned, the statement H400 “Very toxic to aquatic life” may be omitted;"

A similar provision applies to H314 and H318.

QUESTION 2

A source has taken the attached RTECS Data for a liquid substance and consequently concluded that the substance shall be classified as STOT SE2 and STOT RE2.

I consider that making this jump is not justified - but I would appreciate the views of those more toxicology qualified than I am.

The RTECS data provided included a number of routes of exposure that were not applicable to GHS/CLP classification, and omitted some routes for which data are required.

ANSWER 2

[Summary of responses]

The RTECS data provided with the question are not sufficient for the process of GHS/CLP classification. No conclusion can be drawn. Caution should be exercised in using such data-sets.

Given that several data items involved exposure by injection (testicles, muscles, vein) one respondent suggested that the substance might have been under evaluation for use as a therapeutic administration vehicle (and most likely abandoned).

QUESTION 3

I am confused as to how I should write the hazard statements.

In English, the statement would be "Flammable Liquid 2 (Flam. Liq. 2)", however, when I look up SDSs online, "Flam. Liq. 2" is kept in English and just "Flammable Liquid 2" is translated.

Is there a reason for this? Are the short forms universal and English only, as every document I am looking at in various languages keeps it English?

ANSWER 3

In the original version of CLP, for six languages only (Dutch, German, Greek, Hungarian, Romanian & Spanish), the short-forms were translated into the language of that version.

That was changed in January of this year by the sixth Corrigendum to Regulation (EC) 1272/2008, (see OJ L16 20.01.2011), and now the "English" short-form entries appear in all language versions of CLP Annex VI.

 

NOTE:   CHCS Members have access to an acronym listing available in the Member's Only area of this web site.

New and rejoining members of CHCS will be automatically subscribed to the Forum within a few weeks of their joining/rejoining the Society. However, if they wish, new/rejoining members can subscribe as described below at any time before that.

To subscribe to the Forum simply send an email with the Subject "Forum Join", to e-admin@CHCS.org.uk
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The contact information will only be used if there are problems with emails between you and the Forum. Your contact information will be retained by the Forum Operator only, and will not be passed to any third party outside CHCS, even if you request us to do so. Data relating to CHCS Members (only) may be shared within CHCS and then only on the specific request of the Forum subscriber concerned.

You will be sent a message confirming your subscription to the Forum with full details on how the Forum operates.

"Join" messages are only accepted from the address to be used for the outgoing messages; requests to subscribe a third party will be ignored. Advance notice of change of email address will usually be accepted, but may be subject to a confirmatory check. Due to operating constraints, only one address per subscriber may be active at a time. If any email address is no longer valid, it will be automatically deleted. You will need to subscribe again, with a full set of data, from your new address.

When you leave the Forum, all of your data, and any messages with your address on, will be deleted no more than fourteen days later.

Please feel free to mention the Forum to others whom you feel may be interested. Membership of CHCS is a not a requirement for becoming a Forum subscriber.

We look forward to receiving your request to join our Forum.

1. CHCS reserves the right to terminate the Forum at any time.
   
   
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3. Questions and answers and the names of their originators are fully public information. Messages submitted anonymously will be rejected.
   
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For further information on CHCS or the Forum please contact us on: (or to open this address in your email system).

No Messages?

The Forum is not automatic, but is driven by wetware (real human beings). Nonetheless the Forum does not take many breaks. Any break longer than around five days would usually be announced in advance. So if you have seen no messages for a week or more, a filter or other gatekeeper at your end is probably stopping them.

If you are a Forum subscriber whose message flow has dried up, please email the Forum Operator at e-admin@chcs.org.uk to check; but you will need to provide an alternative contact channel for the ForOp to use to respond. (Because otherwise the email reply to your enquiry will fall into the same pit as the Forum messages themselves!)