CHCS  Chemical Hazards Communication Society  Promoting the awareness of chemical hazards & improvements in their identification & communication

CHemical hazards Questions Forum 

CHCS runs an email-based discussion group, known as the Forum, for the mutual support of CHCS members and others with an interest in Chemical Hazard Communication.

With around two-thirds of the Forum subscribers being located in the EU, and around 80% of those in the UK, the Forum has had a natural bias towards European and UK issues. But with the 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, nearly a third of the subscribers were located outside of the UK in thirty-two different 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 free, is simple to join, and is open to anyone anywhere in the world who has a professional involvement in the subject of Hazardous Chemicals (Dangerous Goods) Communication.

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 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.

Examples of recent Questions from the Forum

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

Would anyone be able to advise the threshold limit levels for disclosing 2-Methyl imidazole (CASRN 693-98-1) in Section 3 of the SDS?

ANSWER 1

[Summary of responses]

Based on the REACH Registration dossier, and the proposed harmonised classification, the classification for the substance includes Repr 1B and Carc 2,

Both of these hazard categories result in a threshold for listing in the SDS as 0.1%, according to ECHA’s ‘Guidance on the compilation of safety data sheets’, p 47

That requirement assumes that the overall mixture is classified as hazardous according to CLP.

If the overall mixture is not classified according to CLP for any endpoint, and assuming it is not a gaseous mixture, then there is a general disclosure limit of 1% for hazardous ingredients in section 3 of the SDS: unless the substance happens to be PBT, vPvB or is listed on the Candidate list under “equivalent concern” basis (in which case 0.1% does apply).

With the imminent harmonised classification (14th ATP) of category 1B reprotoxicity, the mixture must be classified at 0.3% of 2-Methylimidazole; but if a mixture has less than 0.3% of this chemical and the mixture is not classified for any reason then legally it would not need to be disclosed. Reference REACH Annex II, 3.2.2

QUESTION 2

Does any quantity of broken package / spill of UN transport classified material need to be notified in every EU country (I have been told that it does in Finland)?

If so, is there a list of the authorities that coordinate this?

ANSWER 2

The incident reporting requirements are clearly defined in ADR 1.8.5.3.

Depending on transport category, the reporting is required for spills greater than 50kg/50L (for Cat 0 or Cat 1) up to 1000kg/1000L (for Cat 4).

For trans-border transport ADR applies. But for local transport, local legislation can be more stringent.

QUESTION 3

Can anyone please comment on why Texanol (R):

2,2,4-trimethyl-1,3–pentanediol monoisobutyrate

CAS RN 25265-77-4

- is classified as a Category 2 Reproductive Toxicant in the USA?

This material is not classified as a Reproductive Toxicant by the European Chemicals Agency (ECHA):

https://echa.europa.eu/information-on-chemicals/cl-inventory-database/-/discli/details/119688

ANSWER 3

[Summary of responses]

Texanol(R) is a commercial product. The Manufacturer's SDS shows that it contains 0.8% of the di-isobutyrate ester (EC 229-934-9, CASRN 6846-50-0). The di-isobutyrate ester is classified (inter alia) as Repr Cat 2, H361d

In the US, different concentration limits are used for the classification of mixtures for reproductive toxicity, compared to the EU (and other jurisdictions). In North America, mixtures containing reproductive toxins of Cat 1A/1B/2 are classified for this effect at a concentration of 0.1%, compared to 0.3% for Cat 1A/1B and 3% for Cat 2 in the EU.

This difference arises from the GHS, where both sets of concentration limits are given with the option for jurisdictions to choose which to use.

In US (and Canada), they have chosen to implement the lower concentration limit as the classification threshold. In most other jurisdictions the higher concentration limits are used as the classification threshold, with a note added to the classification tables, requiring disclosure of the ingredient on the SDS where the substance is present at or above the lower concentration limit.

There are similar issues for sensitisers, carcinogens and STOTS.

Subscribing to the Questions Forum 

Anyone joining CHCS will be automatically subscribed to the Forum, and need take no further action. You can download the Forum's "Conditions" from this link: CHCS Email Forum Conditions.

A non-member of CHCS wishing to subscribe to the Forum should send an email with the Subject "Forum Join", to forop@chcs.org.uk

Please do not include any questions or other Forum content in the message. It will be ignored.

In the message, please give your name as you usually write it. The forename(s) and surname which you give will be into our database and will be shown at the head of any contributions (questions, responses, news) from you that are published as Forum messages.

You will be sent a message requesting consent for CHCS to process your personal information. Without that consent we cannot send you the messages.

Once your consent has been recorded, you will be sent a confirmation message with details on how the Forum operates.

CHCS will record, store, and use for sending the Forum messages, the email address from which the “Forum Join” message was sent. Requests to subscribe a third party cannot be accepted.

Changes of your email address should be sent to forop@chcs.org.uk and the same rules will apply. An address change request may be subjected to a confirmatory check. Only one address per subscriber may be active at a time. If any email address is reported as no longer valid, it may be automatically deleted. In that case you will need to subscribe again from your new address.

When you leave the Forum, please notify forop@chcs.org.uk. Your personal data will be deleted on receipt of that notification.

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.

Notes:

  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. The name of the originating subscriber is shown at the start of each contribution. The name used will be that held in the Forum address book, which will be as set out in the request to join.

  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 the CHCS Office.

No Messages?

The Forum is not an automated bulletin-board, but is a manual email messaging system involving real human beings. Nonetheless the Forum does not take many breaks. Any break longer than around four 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 may be blocking the messages.

If you are a Forum subscriber whose message flow has dried up, please email the Forum Operator at forop@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!)


CHCS News

14th ATP To CLP: Outcomes For TiO2, Cobalt & DPTA
The European Commission has decided the outcome for TiO2, Cobalt and DPTA in relation to the 14th ATP. 

CHCS Members can read more on the CHCS News Briefings page. [Posted on 28 August 2019]

Draft Amendment To "Poison Centre" Regulations On Friday, 19th July 2019, the European Commission sent to the World Trade Organisation, a draft regulation amending Annex VIII, including delaying the 1st notification deadline to 1 Jan 2021.

CHCS Members can read more on the CHCS News Briefings page.

[Posted on 22 July 2019]

Possible Annex VIII to CLP Extension?

The amendment to Annex VIII including adding a one year extension to the first deadline was discussed at CARACAL and there were no objections.

CHCS Members can read more on the CHCS News Briefings page.

[Posted on 22 July 2019]

Endocrine Disruptors - 1st CHCS Video

We have produced our first video for members: "Endocrine Disruptors", which is available to members free-of-charge.

This introductory video explains the various components of the human endocrine system and how they interact, to help understand the mechanisms of endocrine disruptors on human systems.

The video is just over 10 minutes long.

To register for access to the video, please visit our video registration page: Endocrine Disruptors Video Registration.

[Posted on 1 July 2019]

25th CHCS AGM & 8th Annual Lectures

We are delighted to announce that we have a date and venue for our 25th AGM and 8th Annual Lectures:

  • Wednesday 20th November 2019
  • Hilton Birmingham Metropole, Pendigo Way, National Exhibition Centre, Birmingham, B40 1PP

Registration is now open - we will release an agenda and program for the Annual Lectures in due course.

For more details or to register, please visit our 25th CHCS AGM web page. 

[Posted on 13 June 2019]

Autumn Training Schedule Now Published - Courses Available At "Early-Bird" Discount Rate

Full details of all our training courses taking place from now to end of December 2019, can be found on our Training page. All courses are priced at a discount rate of only £275 (+VAT) for each 1-day course (until 9 weeks before the course, when the price rises to £325 (+VAT)).

[Posted on 5 June 2019]

SCHC Fall 2019 Meeting: Registration Now Open 

Our colleagues at the US-based Society for Chemical Hazard Communication have opened registration for one of their major events of the year, which includes a 2-day General Meeting, Professional Development Courses, Networking Events and an Exhibitor Event. This will take place in Arlington, VA, USA with events from 21 - 25 Sept 2019.

CHCS members can attend (or register for web-streaming) at SCHC member rates. For more information, please visit our SCHC web page

News Briefings Summary
  • 29 June 2019
    Workability Issues: Notification to Poison Centres

  • 24 June 2019
    Eurotunnel publishes 2019 guidance

  • 24 April 2019
    HSE Consultation on revision of Workplace Exposure Limits (WELs) for a range of carcinogens


  • 28 March 2019
    Poison Centre Guidance Document Published

  • 22 March 2019
    Poison Centre Guidance Document Published

  • 23 January 2019
    Links To Guidance & Legislation Recently Laid Before Parliament

  • 23 January 2019
    RPA Seeks Input From Companies In Chemicals Supply Chain To Assess Impacts Of Brexit

  • 11 January 2019
    Preparing For A Potential 'No-Deal' Brexit

    CHCS Members can read these News items, and older posts, on the CHCS News Briefings page.

    26 July 2018 - CHCS Labelling Competition

    Have you overcome a tricky labelling problem? Are you labelling a small or awkwardly shaped package, printing on a difficult surface, or have overcome another problem?

    Are you proud of your label designs that make it easier for customers to read and understand your labels?

    CHCS Members can enter our new competition. For more details please visit: CHCS Labelling Competition.

    9  July 2018 - CHCS Needs Your Help!

    CHCS has a number of vacancies on our committees and are looking for volunteers to fill them. For more information please see: CHCS Vacancies.

    Next 3 CHCS Training Courses:

    For a full list of our CHCS Training Courses, please visit our Training page. 

    OTHER CHCS EVENTS

    HOW TO JOIN CHCS

    CHCS Membership is open to any person with an interest in chemical hazard communications. You can join by completing the simple on-line form at Join CHCS. Membership is currently £85.00 (+ £17.00 VAT where applicable; a total of £102.00). 

    Contact CHCS

    • General, membership and events/training enquiries: enquiries@chcs.org.uk, tel+ 44 (0) 333 210 2427 (option 1)

    • For all enquiries related to invoices, payments and any other accounting issues:
      accounts@chcs.org.uk, tel:
       + 44 (0) 333 210 2427 (option 2)

    See full CHCS Contact Details.

    © Chemical Hazards Communication Society

    Privacy Notice
    Data Protection Policy
    Website Privacy Policy



    Powered by Wild Apricot Membership Software