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Poison Centre Notification update November 2020

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Poison Centre Notification update November 2020

A new release of the IUCLID software includes an updated Poison Centre Notification (PCN) format that supports the PCN requirements introduced by the European Commission’s second amendment of Annex VIII to CLP.

The second amendment to CLP/GHS Annex VIII (Poison Centre Notifications) is expected to enter into force in November 2020, following a two-month scrutiny period by the European Parliament and Council. It aims to address concerns raised by industry on the administrative burden for companies while still meeting the information needs of poison centres.

The main changes concern reporting on the composition of mixtures, such as fuels and petroleum products, as well as certain construction products which may be highly variable or sometimes unknown. In summary:

  • For ready-mixed concrete, cement and gypsum, the amendment introduces a list of standard formulas that companies can refer to in their poison centre notifications.

  • Certain fuels that are now listed in the amendment can be notified by referring to their safety data sheet, instead of reporting exact concentration ranges.

  • Cross-sector solutions will be possible for companies that use multiple suppliers for the components of a particular mixture.

  • The last key area of change concerns bespoke paints which are formulated in store at the customer’s demand at the point of sale. The amendment exempts bespoke paints from Article 45 obligations. However, each individual hazardous mixture – meaning the paint base, the tinter mixtures and toners included in the bespoke paints, must still be notified and have their own UFIs.

The updated Guidance on harmonised information relating to emergency health responses, including the second amendment changes to Annex VIII, is currently being prepared. The Draft Guidance can be found on the ECHA website.

Companies that supply mixtures in the EU should start preparing now for compliance under the EU Poison Centre Notification requirements. Key actions to consider:

  1. Communicate with your customers to check whether their end uses are consumer, professional or industrial. If your customers supply to consumers the notifications must be completed by March 2021.

  1. Compile a list of products and their formulations prior to starting notifications.

  1. Allocate a reference number to each product and match it to a UFI.

  1. Ensure labels and SDSs are up to date and can be supplied in the relevant EU Member State official languages.

  1. Obtain full details of containers and take photographs for uploading in the notification process.

  1. Allocate EU Product codes to your products prior to notification. Details can be obtained from the poison centre website.

  1. Decide how to submit your notification by choosing any of the following options:

    1. Directly through the PCN portal

    2. Create information in IUCLID and upload via the portal

    3. Set up a System to System (S2S) service

If you are a non-EU company, you do not have an obligation to prepare a notification. However you may wish to keep the components of your imported mixture confidential, therefore a workaround is to appoint an EU legal entity to notify in the EU on your behalf. Then you can supply the UFI for your notified mixture to your importer, who can then use the UFI, to notify under the PCN.

CEA provides full support to clients to ensure they can meet the PCN requirements. This includes:

  • Preparing notifications on behalf of companies and submitting through the PCN portal (both for EU and non-EU companies)

  • Assisting companies to map their downstream users and collating data required for notifications

  • Reviewing existing SDS’s to ensure compliance, translation services and support preparing new labels and SDS.

If you have a specific question or require further information please contact Peter Godfrey (peter.godfrey@cea-res.co.uk) or Neil Stearn (neil.stearn@cea-res.co.uk).
 
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