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

ECHA Survey On Recycling Of Waste (deadline to respond: 27 April 2021)
The European Chemicals Agency is inviting stakeholders with ‘an interest in chemical recycling’ to respond to a short survey, which will feed into a larger study on chemical recycling of waste. CHCS members can read more on our News Briefings page. [Posted on 26 April 2021]

The Dangerous Goods Emergency Action Code List 2021
The new list has again been produced by the NCEC, in co-operation with the UK Home Office, and is published by TSO. CHCS members can read more on our News Briefings page. [Posted on 26 April 2021]

ECHA Updates Poison Centre Guidance
The European Chemicals Agency (ECHA) have updated their poison centres guidance document. Now on Version 4.0 the updated document gives information on some of the sector specific workability challenges. CHCS members can read more on our News Briefings page. [Posted on 6 April 2021]

CHCS' March 2021 Newsletter is now available, containing important updates on the many recent changes to regulations. See CHCS March 2021 Newsletter. [Posted on 31 March 2021]

Updates to ECHA's Brexit Pages & Q&As
ECHA have updated their Brexit pages and Q&A as well as the guidance on Labelling & Packaging and Annex VIII to CLP. CHCS members can read more on our News Briefings page[Posted on 17 March 2021]

New CHCS Webinar: “Brexit - Do You Know What You Don't Yet Know?”
Thursday 1st April 2021, 14:00 BST. Free-of-charge for members of CHCS, BADGP and SCHC. Visit the Brexit webinar web-page for more details and to register. 
[Posted on 7 March 2021]

Update From HSE On UK REACH
HSE have published a detailed update on UK REACH with several very useful links. CHCS members can read more on our News Briefings page[Posted on 5 March 2021]

The GB Mandatory Classification and Labelling (MCL) List includes decisions made in the 14th and 15th ATPs to the EU-CLP Regulation, which are not yet required to be complied with.
CHCS members can read more on our News Briefings page[Posted on 1 February 2021]

Update to Canada GHS (Aligned with 7th Edition)
Regulations Amending the Hazardous Products Regulations (GHS, Seventh Revised Edition) and the Order Amending Schedule 2 to the Hazardous Products Act were published in the Canada Gazette, Part I on December 19, 2020.
CHCS members can read more on our News Briefings page[Posted on 26 January 2021]

UK Exit Of EU: Resources To Help As Transition Period Ends
CHCS members can read more on our News Briefings page[Posted on 11 December 2020]

End Of UK Transition Period – HSE Podcasts Series
HSE is hosting a series of podcasts over the coming months to provide more information on the changes to how chemicals will be regulated from 1 January 2021. CHCS members can read more on our News Briefings page[Posted on 9 December 2020]

Second Amendment Of Annex VIII of CLP (Poison Centres) Is Published
The second amendment to Annex VIII to CLP, concerning poison centres was published in the Official Journal on 13 November 2020 and entered into force on 14 November 2020. CHCS members can read more on our News Briefings page[Posted on 23 November 2020]

New "Brexit" Web Pages 
As the end of the transition period is nearly upon us (31 December 2020), and we are starting to learn more about the changes to our own regulations and our future relationships with the EU, we are pleased to present you with several new web pages on specific Brexit-related topics. Please visit our website Brexit page. [Posted on 13 November 2020]

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]

News Briefings Summary
  • 30 October
    Poison Centre Portal Updated

  • 24 August
    Member States Slowly Starting To Use The New Portal

  • 22 June 2020
    Option To Anonymise The Unique Formula Identifier (UFI)

  • 26 May 2020
    New ECHA CLP Guidance Documents Published

  • 19 May 2020
    Draft Regulation Amending Article 25 Of CLP

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

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