Service Bulletin

Sending of Forum messages is again being impacted by changes in the use of blocklists. Currently the problem seems to be the lists of contact domains used by spammers (URI_ Bls).

If you are a Forum subscriber whose message flow has dried up, you can email the Forum Operator to check; but you need to provide an alternative contact channel for the ForOp to respond (because any email reply to your enquiry will fall into the same pit as the Forum messages themselves).

With a large proportion 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 GHS on the horizon, and the magnitude of international trade (especially in preparations) there are many outside the UK who consider it worthwhile to subscribe - in at least fifteen countries.

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

The Forum is free, open to anyone anywhere in the world with an interest in the subject, and is easy to join.

Forum Subscribers submit for publication questions, responses, general comments or news items (for example the publication of a new Regulation). The only restriction in scope is that submissions should be be relevant to Chemical Hazard Communication (CHC) matters.

Submissions are made by email to the Forum Operator, who also acts on behalf of CHCS as the primary moderator.

The messages are then given a reference by the Forum Operator (multiple responses to questions are usually combined into single messages), and emailed to the whole of the subscription list. The subscription list 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

I work for a company which currently purchases various raw chemicals and either blends them to sell them on under our companies relevant trade name, or re-sells the chemicals (without altering the chemical in any way).

What are the company’s responsibilities regarding REACH? Are we obliged to register or pre-register all or some of the above chemicals whether they are blended or re-sale (unchanged) chemicals.

ANSWER 1

Your company only need to pre-register or register if you import a substance (either on its own or in a preparation) from outside the EU or if you manufacture, inside the EU, a substance that is in scope. To be in scope your company must be import or manufacture more than 1 tonne /year.

Your description of blending suggests there is no chemical reaction producing another substance. Therefore you are not the manufacturer of another substance.

Those substances that are re-sold by you must be (pre)registered by the EU manufacturer or EU importer (assuming they are in scope of the regulation), but not by your company.

Your duties under REACH will apply to your role as a downstream user. 

See also  http://www.hse.gov.uk/reach/helpdesk.htm or the ECHA site at http://www.echa.europa.eu.

QUESTION 2

Is labelling according to the DSD/DPD, in English only, acceptable across Europe, or do some countries require their own national language for (presumably) the safety and risk phrases ?

Is there any easy way of finding out what these requirements are?

ANSWER 2

NO - English labelling per the DSD/DPD is only acceptable in the UK, as English is the de facto official language of the UK and in Ireland, as the Irish, in their national implementation of the DSD and DPD, have not required that any other language than English be use.   Note the DSD and DPD give MS  the right to make use of their official languages a requirement.

Incidentally in the UK national implementation* of the DSD and DPD  you will see no mention of the use of English, but the Regulations refer to use of wording for the indication of danger statement and the risk and safety phrase specified in a publication that is printed only in English.
*The Chemicals (Hazard Information and Packaging for Supply) Regulations 2002 {SI 2002 No. 1689 - in short CHIP3 or just CHIP} as amended for Great Britain, and equivalent Statutory Rules for Northern Ireland.

All other Member States (MS) have made the use of their official languages mandatory, in one way or another.

As far as I am aware there is NO easy way to find out what the official languages of the MS are.

QUESTION 3

Methylhydrazine (UN1244) is forbidden for transport by air unless you obtain competent body approval after demonstrating that the shipment can be done safely.

Does anyone know why methylhydrazine is forbidden for air transport?

ANSWER 3

Under the IATA regulations section 3.6.1.4, Liquids having a vapour inhalation toxicity of Packing Group I are forbidden on both passenger and cargo aircraft. Information available (eg in IMDG Code – which describes “properties and observations”)  would suggest that methylhydrazine may be banned for air transport because it meets the Packing group I criteria for toxicity by vapour inhalation.

 

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

To subscribe to the Forum simply send an email to e-admin@CHCS.org.uk.

In the subject line put "Forum Join". In the body of the message, give your name (in the form you wish it to appear at the head of your contributions), your address, and your telephone/fax contact details. If you are a current member of CHCS, please include that information.

We will only use the contact information 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 (including the CHCS Office) even if you request us to do so.

You will be sent a message confirming your membership of the Forum and 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.

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.
   
   
2. Whilst CHCS in general and the operator of the Forum in particular will use their best endeavours to ensure the accuracy and legality of the information transmitted the Forum messages do not create any liability or responsibility in any way for CHCS and/or its officers and members.
   
   
3. Questions and answers and the names of their originators are fully public information. Messages submitted anonymously will be rejected.
   
   The name of the originating subscriber is shown at the start of each contribution. The name used will follow this precedence:
   • the name (and any affiliation) shown at the start of the original submission;
   • the name at the end of the submission;
   • the name in the Forum subscriber address book.
   
   Requests to withhold the name of the originator will be considered - on a case-by-case basis - only when the submitter is known, reasons are given, and the circumstances are compelling.
   
   Postal addresses appended to signatures will be included in the messages sent out, but originators' email addresses and telephone numbers will always be removed unless the originator specifically requests on each occasion that these be included in their contribution.
   
   
4. The Forum is not a bulletin board. You can only see the messages if your email address is on the subscription list held by the Operator.
   
   
5. The forum is run by a CHCS volunteer. No service guarantee can be assumed or is given.

For further information on CHCS or the Forum please contact us on chcs@chcs.org.uk.