SAFER CHEMICAL CONFERENCE: looking for a European chemical industry more environmentally friendly

How are we delivering on safer chemicals?

How can companies prepare for the new EU obligations on chemicals kicking in next year?

These are the questions that the European Chemicals Agency ECHA wanted to address in its 2020 edition of the Safer Chemical Conference, a training meeting between experts that analyzed the main European lines of action implemented in the chemical industry with the aim to contribute to protecting the health and environment of EU citizens.

It was developed in three sessions, but in Siam we were very attentive to Session 3, held on June 2, which offered a multidisciplinary vision on harmonized toxicological reporting. Below, we analyze its key points.

The session began with the conference Harmonised information improving emergency response in poison centres, in which Javier Sánchez Saez, member of ECHA, explained the motivation behind the new european harmonized toxicological notification format. The presentation showed that the new system has been designed to facilitate emergency health response.

Consumers and workers come into daily contact with hazardous chemicals, and although Chemicals are expected to be used according to safe use instructions, unintentional exposure may happens: ingestion, skin contact, inhalation, etc. In those cases, Emergency professionals need a rapid product identification, information about the Chemicals contained and its Hazardous properties, all these in order to facilitate the Identification of the correct treatment and Avoid further damage.

Annex VIII to CLP develops the European harmonised notification to the Poison Centres.According to the ECHA, “ It’s about harmonisation, and harmonisation brings synergies and efficiencies”. In practice, the new system implies:

• •Same information requirements in all EU Member States.
• •Preparation of data in a harmonised format.
• •Submission of data possible via central system (ECHA Submission portal).

Today, Germany, Estonia, Lithuania and Denmark already accept harmonised notifications, but all the rest member states will wait until 1 January 2021.

This new system, although efficient and beneficial in the long term, also implies a new complex notification process for companies, which will have to notify their products in the different languages of each country in which they are marketed, pay different national taxes, etc. Therefore, our CHEMETER software will offer an additional module that issues automatic notifications in a few minutes.

The following conference was given by Kirsi Myöhänen, who spoke about How to apply the UFI code in labeling. A UFI code is an obligatory supplemental information on the label (CLP Article 25(7)). It is normally included in the label section for supplemental information, but can alternatively be placed outside the label by printing or affixing it directly onto the inner packaging. It must be located with (right next to) the obligatory CLP label elements, such as product identifiers or hazard information. UFI in labelling must be clearly visible, legible and indelibly marked or firmly attached if e.g. a sticker is used, and multi-component products have separate labels for each component – separate UFIs for each label/component.

This is, once again, a complex system, especially in products with special characteristics, for which ECHA has developed the following Guidance on labeling and packaging.

During this third session there was also space for the analysis of the concrete impact on a company of the new notification system. During the presentation Get ready to notify: industry perspective, Wojtek Popielarz, from the Reckitt Benckiser group, brought the perspective of the detergent industry.

Although he acknowledged that PPC notifications harmonisation will improve emergency health response and that central use of ECHA notification portal could drive some efficiency, the number of notification is expected to significantly increase, and the producers of detergent have already experience workability issues regarding the new system:

• •Insufficient time prior to deadline to assimilate notification tools.
• •Regular product variations: Technically equivalent raw materials from different sources used interchangeably. Those RMs can vary in their discrete compositions, that will lead to multiple & frequent changes of UFI for the same product.
• •UFI location: If required on all packaging layers, it would cause unnecessary complexity & not consumer relevant.
• •GPI: Generic Product identifier only for non hazardous fragrances. Most fragrances are hazardous within detergent industry Increase number of components disclosed (a single fragrance can contain up to 200 components), which will lead to more frequent PCN updates.

It is expected modifications or adjustments in the process in order to make it more practical, but he came with the conclusions that “The key for industry is to understand the impact, engage with suppliers, adapt systems and processes and plan implementation in advance.”

Maria van Kooij and Marc Willemse, from the European Council of the Paint, Printing Ink and Artists' Colours Industry (CEPE), offered at their conference Notification tools: paint industry perspective an analysis of harmonized notification from the perspective of their industry.

Marc Willemse, part of the Chugoku Paints B.U. and the CEPE addressed the paint industry perspective about working with the ECHA Submission portal, and here are his conclusions:

• •Navigation is complicated, too many clicks.
• •Duplicate data entry.
• •Not always directly clear if you made a wrong input, validation at the end of process.
• •Notification via Guided Dossier Preparation took approx. 2 - 3 hours.

He encouraged companies to be proactive and learn from the ECHA Submission Portal system now, test and provide feedback. And concluded that although al lot of work has already been done, “for all stakeholders to meet new requirements a lot of work will follow”.

In her online talk, Maria Van Kooij, from AzkoNobel, pointed out her company experience (preparing for) system-to-system integration. According to her, there is a need for managed automation due to:

• •Tens of thousands of products to be notified.
• •Frequent formulation changes. Partly own initiative, partly by raw material suppliers or driven by legislation changes.
• •Not feasible to do notifications & updates manually. Notifications must be generated in bulk.
• •Automation requires standardization. The solution must work for thousands of notifications at a time.

She explained AzkoNobel current approach for automation: focus on own manufacturing first and automate what they can.

She concluded that, although “There is no magic button for Automating PCN notifications, but business can engage early in the process and adapt to every different scenario”.

Siam shares this approach: chemistry industry companies need an intuitive software that automatically generates hundreds of notifications just in a few minutes. For this reason, we are working on an additional module for our CHEMETER system.

If you want more information about its current characteristics and everything it can do for your company, you can access the section: Chemeter, safety data sheet software