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


New CHCS Webinar: "An Introduction To In Silico Toxicology – (Q)SAR And Read-Across"
To be presented by Dr. Elena Fioravanzo, of ToxNavigation Ltd. 15 September 2020, 13:30 BST. Register Now (free of charge for members of CHCS).  [Posted on 24 July 2020]

CHCS Statement On Coronavirus / COVID-19
In response to the uncertainty around the COVID-19 pandemic, we have prepared a statement on how we are responding to the challenges this raises. You can read the current statement at: Coronavirus / COVID-19. We will update this as and when necessary[Updated on 19 May 2020]

Option To Anonymise The Unique Formula Identifier (UFI)
The Unique Formula Identifier (UFI) generator has been updated to allow companies to chose not to use their company VAT number to create their UFIs.
CHCS members can read more on our News Briefings page[Posted on 22 June 2020]

New ECHA CLP Guidance Documents Published 1) Guidance on labelling and packaging
2) Guidance on harmonised information relating to emergency health response.
CHCS members can read more on our News Briefings page[Posted on 26 May 2020]

Draft Regulation Amending Article 25 Of CLP
The Draft Commission Delegated Regulation amending Article 25 of Regulation (EC) 1272/2008 of the European Parliament and of the Council on classification, labelling and packaging of substances and mixtures as regards bespoke paints is now available. CHCS members can read more on our News Briefings page. [Posted on 19 May 2020]

Draft Second Amendment to Annex VIII of CLP
The European Commission have published the Draft Commission Delegated Regulation amending Regulation (EC) No 1272/2008 of the European Parliament and of the Council on classification, labelling and packaging of substances and mixtures. This is the second amendment to Annex VIII of CLP, otherwise known as poison centres. CHCS members can read more on our News Briefings page. [Posted on 23 April 2020]

Reminder: 13th ATP to CLP applicable from 1st May 2020
The 13th Adaptation to Technical Progress (ATP) to the Regulation on the classification, labelling and packaging of substances and mixtures (CLP) is applicable from 1 May 2020 and contains updated classification and labeling for a number of substances. CHCS members can read more on our News Briefings page. [Posted on 23 April 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
  • 23 March 2020
    Multilateral Agreements For ADR & RID

  • 17 March 2020
    The Carriage of Dangerous Goods and Use of Transportable Pressure Equipment (Amendment) (EU Exit) Regulations 2020

  • 3 March 2020
    UK Chemical Industry: Regulatory Divergence

  • 2 March 2020
    Corrigendum To the 14th ATP Published

  • 10 February 2020
    Third Corrigendum To ADR 2019 Published

  • 13 January 2020
    Poison Centres - Annex VIII amendment published

  • 21 November 2019
    CHCS 2019 AGM & Annual Lectures: Presentations Now Available

  • 21 November 2019
    Commission Directive (EU) 2019/1831 Establishes  A 5th List Of Indicative Occupational Exposure Limit Values (IOELVs)

  • 12 November 2019
    ECHA publishes draft CoRAP for 2020-2022

  • 22 October 2019
    GHS Revision 8

  • 21 October 2019
    Model Regulations, 21st Revised Edition

  • 20 October 2020
    IATA Publishes Significant Changes To The 61st Edition Of The Dangerous Goods Regulations

  • 20 October 2019
    CHCS October 2019 Newsletter Now Published

  • 1 October 2019
    Draft amendment to REACH Annex II

  • 30 September 2019
    Poison Centre First Deadline To Be Postponed

  • 23 September 2019
    Updated advice for UK-based companies intending to export chemicals listed in the Prior Informed Consent (PIC) Regulation to EU countries in the period immediately following the UK’s withdrawal from the EU

  • 28 August 2019
    14th ATP To CLP: Outcomes For TiO2, Cobalt & DPTA

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

    Next 3 CHCS Training Courses:

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

    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). 

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