KFT Goes to Hollywood

People say that a picture says a thousand words. How much more do movies say? But how can a film cover the complex topic of regulatory chemical compliance? And how could anyone develop a meaningful plot based on it?

Regulatory chemical compliance appeals to our desire for safety and security, so it also deals with trust. Customers and users want trustworthiness and transparency. They want to be sure that a product actually contains what the label indicates and that the label indicates what a product actually contains– and they want to do both seamlessly. Those who take that to heart will have fans on their side. In short: Brands that want to be seen as likeable and reputable should at least do what the law requires.

But enough with the words: Let the pictures speak!

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China: New Information Platform for Hazardous Chemicals

China‘s National Registration Centre for Chemicals (NRCC) has launched a new, integrated information platform (in Chinese). The platform enables companies to search for registrants of hazardous chemicals and the products they have registered.

The test phase runs until October 2019. According to remarks made by the NRCC to Chemical Watch, the new platform should be fully functional after that date. So far, it is unknown if the platform will operate in Chinese only or in English as well.

The platform offers information on

  • The classification of chemicals listed in the catalog of hazardous substances
  • GHS classifications and characteristics
  • Policies and regulations
  • Technical support services for accidents
  • Accident reports
  • Training videos in Chinese

Users can search for:

  • English substance names
  • Chinese substance names
  • CAS numbers

Manufacturers and importers of hazardous chemicals must register the substances with the NRCC according to State Administration of Work Safety (SAWS) Regulation 53. The SAWS Regulation supplements Decree 591, which applies to the manufacture, storage, use, and marketing of substances considered highly poisonous.

Note: SAWS was renamed the Ministry of Emergency Management (MEM) in 2018.

For questions about labeling requirements in China, the creation of safety data sheets, or the registration of new chemicals please contact us at sds@kft.de.

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Public Availability of Database of Chemicals Related to Plastic Packaging

A group of non-governmental organizations, including The Food Packaging Forum, ChemTrust, and ChemSec, have published a database of chemicals related to plastic packaging developed in collaboration with research institutions in Europe and the United States. The database contains information on over 4,000 materials that are used in plastic packaging. The developers used several sources for the information, including the database of the U.S. Environmental Protection Agency, Chemicals and Products Categories database (CPCat), books, and professional reports on the use of chemical substances in plastics. The extensive article on the database appeared in Science of the Total Environment and is available here as a preprint. The chemical databases are also available there as supplemental information for downloading.

In their article, the authors emphasize the importance of collaboration with industry, government agencies, and other stakeholders to enable the closure of scientific gaps. That’s the only way to enable fact-based risk evaluation. The primary goal is to find substitutes for the most-dangerous chemicals as quickly as possible.

Jane Muncke, project manager and managing director of the Zurich-based Food Packaging Forum said that the database is not yet complete by any measure. Why? No uniform toxicity classification yet exists for the chemicals, and companies consider the contents of their packaging as confidential business information. That’s why information does not flow along the supply chain, which limits effective protection of human health and the environment.

Ensure that your products do not harm human health in any way. If you have any questions about the laws involved, we are pleased to partner with you. Contact us at reach@kft.de.

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California Considers Listing Nickel as a Reproductive Toxicant

The California Office of Environmental Health Hazard Assessment (OEHHA) is considering classifying nickel and nickel compounds and including them in a DART Proposition 65 listing. The Developmental and Reproductive Toxicant Identification Committee (DARTIC) wants to discuss the matter and make a decision at its meeting on October 11. If the participants vote for inclusion on the list, the use of nickel would be restricted, with a huge effect on the industry. Nickel is used in steel alloys, catalyzers, batteries, and pigments.

The Nickel Institute, a global association of leading nickel producers, stated that the move in California was a surprise. The initiative is particularly shocking, says the Institute, since the bioavailability of nickel is much lower, exposure to nickel in the workplace is limited, and appropriate measures already regulated safety there.

In fact, the hazards posed by nickel and its compounds have been evaluated by agencies around the world many times over, and its negative effects on health and the environment are well known. Consequently, many nickel substances are already included in the Proposition 65 list because of carcinogenicity. Only nickel carbonyl is listed under DART. In the EU, water-soluble nickel compounds are classified as substances with cancer-causing properties of Category 1B in the CLP Regulation. No corresponding classification exists for nickel in metal form and insoluble nickel compounds.

The studies undertaken to date have focused on skin sensitization and carcinogenicity. More-recent evaluations are based on the results of several recent epidemiological studies that are summarized in a 342-page document. Public comments on the document can be made up to September 11 as part of a public consultation.

Ensure the safety of your products at all times. We can help. Contact us at reach@kft.de.

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Legal Gaps in Dealing with Endocrine-Disrupting Chemicals

The member states of the EU and non-governmental organizations have called for uniform legal regulations when dealing with and identifying endocrine-disrupting chemicals (EDC). That’s the result of a feedback period as part of an EU initiative, “Towards a more comprehensive EU framework on endocrine disruptors.” The EU has proposed a road map and wants to use the initiative to inventory information on EDCs and sketch out any measures needed in the future.

A wide variety of professional associations, research institutions, governmental agencies and organizations (including the German Environmental Ministry: UBA) submitted 44 answers to the EU before the deadline on July 19.

Some stakeholders criticized the road map as not extensive enough. The UBA, for example, suggested a “more ambitious” EDC strategy. It said that broader measures than those previously taken are needed to expand scientific knowledge about EDCs quickly. The Ministry proposed detailed activities with verifiable goals and clear timing.

The Belgian Federal Service of Health, Food Chain Safety and Environment (FPS) was concrete. Its representatives condemned silo-thinking and called for cross-sector conversations and legal solutions. Laws should not only cover biocides and pesticides, said FPS, but also toys, cosmetics, materials that come into contact with food, and building materials.

At the end of May, the umbrella group, Health and Environment Alliance (HEAL) held a meeting in Brussels where several members of the European Parliament, governmental representatives from individual countries, and scientists presented the status of their knowledge about EDCs.

If you have any questions about EDCs, please contact us at reach@kft.de.

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India: Registration Guidelines for Biocides in Paints

India’s Central Insecticide Board and Registration Committee (CIB&RC) has published Registration Guidelines for Biocides in Paints. The requirements for these substances are less comprehensive than those for traditional biocides. However, their applicability is correspondingly narrow.

The following restrictions apply, so that biocides may be used:

  • Only to extend the shelf-life of paints or as a paint or thin-film preservative
  • Only for purposes other than agriculture
  • Only if they do not claim to kill or repel insects, inhibit mold, or reduce odors from bacteria

Thomas Mueller, managing director of India’s Auxilife Scientific Services, told Chemical Watch that as soon as a technical grade active ingredient (TGAI) can be used as a biocide or plant protection product, the regulations for pesticides apply. The goal of the guidelines is to prevent the use of biocides in agriculture.

In the EU, the use of biocides in paint is regulated in the Biocide Regulation, Regulation (EU) No. 528/2012. They are listed in main group 2, product type 6.

Please contact us at biocides@kft.de if you have any questions.

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GHS Mandatory for All OECD States

The Organization for Economic Co-Operation and Development (OECD) has made the Globally Harmonized System of Classification and Labeling of Chemicals (GHS) mandatory for member states and prospective members.

The implications of the decision are limited, said Bob Diderichs, director of the OECD’s environmental division, in a conversation with ChemicalWatch, given that all OECD states have already implemented the system. New applicants are also required to implement GHS regulations before joining the organization.

The obligation is part of a more extensive law that seeks to reduce the risks of chemicals across the OECD and that was approved by the OECD Council at the end of May.

The new law replaces the previous law of 1991. The old law required member states to “cooperatively investigate” chemicals with a high production volume (HPV) and thereby identify the health and environmental hazards of the substance. Individual countries were to establish appropriate measures and programs to minimize the risks.

With the new law, the OECD seeks to achieve harmonized and collaborative assessment methods and provide better dissemination of information.

The OECD currently has 36 member states. Columbia became the newest member in May.

If you need any support related to GHS guidelines, please contact us at sds@kft.de.

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ECHA Issues Deadline for SVHC in Articles

Companies that manufacture, import, or sell articles containing substances of very high concern (SVHC) must notify the ECHA about the articles by the end of 2020. The ECHA will set up the related database by the end of 2019, according to a press release.

The goal and purpose of the database are to:

  • Support waste-handling and recycling companies in reclaiming raw materials from waste products with as little hazardous material as possible.
  • Serve consumers as a foundational repository of information: It could be possible to provide the
    information stored in the database to app users, for example (We reported on a related project of the German Environmental Ministry)
  • Encourage companies to replace the SVHC with alternatives as quickly as possible

According to Article 7 (2) of REACH, companies are obligated to notify the ECHA when articles contain a concentration of SVHC greater than 0.1% by weight in quantities greater than one ton per year and per producer or importer. According to Article 33, Section 2, they are to respond to consumers’ requests for information about their articles within 24 days when the concentration of the substances therein exceeds 0.1% by mass.

As part of the EU action plan on the circular economy, the EU Council of Ministers called on the ECHA at its meeting on June 25 to take measures that enable seamless tracking of hazardous chemicals along the entire supply chain by 2030 (see No. 16 of the document).

Only recently has the EU Parliament approved an amendment of Article 9 of the Waste Framework Directive. As is also true of REACH, the reformulated Article 9 calls on manufacturers and importers to notify the EC-HA of the presence of all SVHC in their articles (see our blog entry: EU Amends Article 9 of the Waste Framework Directive).

With our support, you can comply with all legal requirements when dealing with chemicals with possible health issues. We are here for you at reach@kft.de.

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