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 publishes draft CoRAP for 2020-2022
ECHA has announced a draft plan incorporating 74 substances proposed for evaluation by Member States (MS) during 2020-2022, under the Community rolling action plan (CoRAP).  CHCS members can read more on the CHCS News Briefings  page. [Posted on 12 November 2019]

CHCS October 2019 Newsletter Now Published

Our October 2019 Newsletter is now available, which includes an in-depth, special report titled "Titanium Dioxide - Stakeholders Demand An Impact Assessment". See our CHCS Newsletters page for more details [Posted on 20 October 2019]

GHS Revision 8
Globally Harmonised System (GHS) Revision 8 has been published and is available online in both English and French. CHCS members can read more on the CHCS News Briefings  page. [Posted on 22 October 2019]

Model Regulations, 21st Revised Edition The United Nations Recommendations on the Transport of Dangerous Goods, Model Regulations, 21st Revised edition is now available in English and French. CHCS Members can read more on the page. CHCS News Briefings  [Posted on 21 October 2019]

IATA Publishes Significant Changes To The 61st Edition Of The Dangerous Goods Regulations  

CHCS Members can read more on the CHCS News Briefings page.   [Posted on 20 October 2019]

CHCS & SCHC Sign New MoU
We are delighted to have signed a new MoU with the Society for Chemical Hazard Communication, outlining the relationship between both Societies and the benefits to members of both. For more information visit our SCHC web page [Posted on 18 October 2019]

CHCS AGM & Annual Lectures - Celebrating 25 Years of CHCS
We are delighted to publish our draft program for the event, including speakers and presentation titles. 

There is still plenty of time to register for the event, which takes place on 20 November at Hilton Hotel, NEC, Birmingham. Free of charge for CHCS members. 

To find out more, download the flier or reserve your place please visit the CHCS 25th AGM event page [Posted on 8 October 2019]

Draft amendment to REACH Annex II
A consultation has been opened on the draft amendment to Annex II of REACH. The draft has also been notified to the World Trade Organisation – G/TBT/N/EU/680.  

CHCS Members can read more on the CHCS News Briefings page.  [Posted on 1 October 2019]

Webinar Series: "Introduction to Chemical Management in Latin America"
Our colleagues in the US-based Society for Chemical Hazard Communication (SCHC), have developed a series of webinars, each covering a different country. CHCS members can register at SCHC-member prices. For more details, see our SCHC web page.  
[Posted on 25 September 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]

News Briefings Summary
  • 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

  • 22 July 2019
    Draft Amendment To "Poison Centre" Regulations

  • 22 July 2019
    Possible Annex VIII to CLP Extension?

  • 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.

    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, events, training, invoices, payments, etc. enquiries:

      enquiries@chcs.org.uk, tel+ 44 (0) 333 210 2427

    See full CHCS Contact Details.

    Join our Mailing List

    © Chemical Hazards Communication Society

    Privacy Notice
    Data Protection Policy
    Website Privacy Policy



    Powered by Wild Apricot Membership Software