Recent updates have introduced new hazard classes under the CLP Regulation, necessitating clear guidance for stakeholders. This publication provides an overview of these new hazard classes and the key points from ECHA’s guidance.
Understanding the New Hazard Classes
The introduction of new hazard classes under the CLP Regulation addresses emerging chemical risks that were not adequately covered by previous classifications. These classes include:
- Endocrine Disruptors (EDs):
– Chemicals that interfere with hormonal systems can cause adverse effects in humans or the environment.
– Subcategories:
– Category 1: Known or presumed endocrine disruptors.
– Category 2: Suspected endocrine disruptors.
- Persistent, Mobile, and Toxic (PMT) Substances:
– Substances that persist in the environment, demonstrate high mobility in water, and are toxic to aquatic life.
- Very Persistent and Very Mobile (vPvM) Substances:
– Similar to PMT but without the acute toxicity requirement, these substances pose long-term environmental risks due to their high mobility and persistence.
Key Elements of ECHA’s Guidance
ECHA’s guidance on these new hazard classes aims to provide clarity on classification criteria, methodologies for hazard assessment, and practical steps for compliance. Below are the essential aspects:
1. Hazard Identification
– Endocrine Disruptors:
– Use of internationally recognized test methods (e.g., OECD guidelines).
– Assessment of adverse effects and endocrine activity.
– PMT and vPvM Substances:
– Evaluation of persistence (P), mobility (M), and toxicity (T) based on existing data or new studies.
2. Data Requirements
– Comprehensive datasets are required for classification, including:
– Physicochemical properties.
– Environmental fate.
– Toxicological profiles.
– ECHA emphasizes the use of read-across, QSAR models, and weight-of-evidence approaches where direct data is unavailable.
3. Risk Communication
– Updated labels and safety data sheets must include the new hazard information.
– Companies must ensure that downstream users are informed about these new classifications and their implications.
4. Compliance Deadlines
– Transitional periods have been established for the implementation of the new classifications. Companies are encouraged to act promptly to avoid non-compliance.
Implications for Stakeholders
The introduction of these new hazard classes has significant implications for manufacturers, importers, and downstream users of chemicals. Key actions include:
– Revisiting Classification and Labelling: Companies must evaluate their product portfolios to determine if any substances meet the criteria for the new hazard classes.
– Updating Safety Documentation: Safety data sheets and labels must reflect the new classifications.
– Training and Awareness: Employees and supply chain partners need to understand the implications of the new hazard classes.
ECHA’s Support Resources
To assist stakeholders in navigating these changes, ECHA offers a range of resources, including:
– Guidance Documents: Detailed criteria and examples for classification.
– Webinars and Workshops: Interactive sessions to explain the new hazard classes.
– Helpdesk Support: Tailored advice for specific queries.
Conclusion
The inclusion of new hazard classes under the CLP Regulation represents a critical step forward in addressing emerging chemical risks. ECHA’s guidance provides a robust framework for stakeholders to understand and implement these changes effectively. By staying informed and proactive, companies can ensure compliance while contributing to a safer environment and healthier populations.
For more detailed information, visit ECHA’s official website or consult the full guidance documents on the new CLP hazard classes
