CLP 2015 Activities of the German Helpdesk

Transcription

1 CLP 2015 Activities of the German Helpdesk Dr. Andreas Fleischer, BAuA EU Commission Workshop on the safe use of chemicals by SMEs; 16th September 2014

2 REACH-CLP-Biozid Helpdesk: answering enquiries 3200 enquiries in 2013, 20 % on classification and labelling close cooperation and integration into ECHA HelpNet (Network of national Helpdesks, aims to harmonise advice on REACH, CLP, Biocides) target group SME: individual, tailor-made answers - but no consultancy role telephone contacts of expert provided with answer personal talks: possibility to meet us in Dortmund

3 CLP 2015: Examples for current activities ###screenshot clp webseite###ggf. preview

4 Information event on C&L of mixtures Target Group: SME 2 days event: day 1: 250 participants, presentations on C&L of mixtures day 2: 80 participants, practical workshop / hands on training high information demand: fully booked 24h after announcement, already 90 potential participants on waiting list, requests for second event high awareness (?): at least very efficient list and RSS feed of website for event announcement plans to continue events on mixture C&L and supply chain obligations, also for inspectors

5 New Website section: CLP - Mixtures 2015 Links to step-by-step guides, Posters, Brochures, FAQ, Guidance and ECHA website e.g. step-by-step guides (BAuA, ECHA) on mixture classification: address common problem: confusing amounts of new and not harmonised data strategies: how to identify/examine/evaluate data role of public inventories: C&L inventory, disseminated data of REACH registrations

6 Examples for frequently asked questions: labelling Why are people always talking about diamonds?... because they are beautiful?... because CLP is like a raw diamond, it gets polished and shinier by ATPs? source: Rob Lavinsky, irocks.com CC-BY-SA-3.0 [CC-BY-SA-3.0 ( via Wikimedia Commons

7 Colour of the pictogram Hazard pictograms [...] shall have a black symbol on a white background with a red frame sufficiently wide to be clearly visible What kind of red?? shades of red... Helpdesk recommendation: colour as in pictograms published at possible to take over tones used for e.g. traffic signs (RAL 3020)

8 How to measure (minimum) dimension of pictograms 10 mm 10 mm 10 mm 10 mm No! Yes!

9 Avoid unnecessary testing! Example: -Mixture contains sensitizing substance in concentration which leads to classification (calculation method) -Test data of mixture suggest no classification Question: Do I need to label with EUH208 "Contains (...). May produce an allergic reaction"? Answer: Yes! (If sensitizing substance in mixture is above thresholds in table 3.4.6) Don t test mixtures for sensitization (and almost all other health/environmental hazards)! Animal welfare! Use conventional calculation methods for those endpoints! This specific case: testing does not help, label with EUH 208 is necessary anyway. Further reason for SME: tox-test are expensive!

10 Fold out labels, many languages Difficult question as a thought starter: May I use fold out labels to cover 15 languages on my mixture? Answer in guidance, implied by current legal text (CLP Articles 29, 31, 32): [...] may not be used where a label becomes unreadable because the supplier has chosen to add more languages on a label than are required in the Member State where the substance or mixture is placed on the market. Good reason: One should see and understand label elements at first sight. Currently for Helpdesk no possibility to give other advice High impact on SME who supply their mixtures (with low quantities) to several EU-Member States Helpdesk tries to help with referring to possibilities for reducing label elements (Annex I section 1.5.2) to gain space on the label

11 How to reach us Bundesanstalt für Arbeitsschutz und Arbeitsmedizin (BAuA) Friedrich-Henkel-Weg 1-25 D Dortmund Telefon (service-telephone) Fax Internet - thank you for your kind attention -