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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Cosmetics: New Rating System Should Drive Sustainability

A U.S. non-profit organization, The Sustainability Consortium (TSC) and retail companies Walmart and Target have published a rating system for the personal care industry that they developed as part of a joint project with other partners. The point system, an industry scorecard, should help manufacturers develop sustainable and safe products.

The core of the rating system consists of 32 key performance indicators that are divided into four areas:

  • Human health impact of ingredients and product formulations
  • Resource usage and emissions during sourcing, manufacturing and product use
  • Ingredient disclosure to consumers
  • Environmental and health impacts of packaging

Most of the points (130 of 400) are awarded in the human health cluster, which covers the ingredients of cosmetics and the related safety concerns. For example, companies win points when their products do not contain anything that appears in one of the pertinent lists of hazardous substances, such as the Californian Prop 65 list of substances suspected of causing cancer, the EU priority list of endocrine disruptors, and the list of carcinogenic, mutagenic and toxic to reproduction (CMR) substances in Annex XVII of REACH. Companies win extra points when an independent third-party certifies their products as featuring quality and enhanced safety.

As early as three years ago, Walmart, Target, and the non-profit Forum for the Future (FFTF) began work on the rating system project as part of the 2014 beauty and personal care (BPC) product sustainability summit. They were later joined by other organization, including Henkel, Johnson & Johnson, and the Environmental Defense Fund (EDF).

Many retail groups welcome the rating system. Along with Walmart and Target, retailers CVS Health, Sephora, and Walgreens want to develop their own systems on this foundation. “We believe that, over time, this tool will be valuable in both evaluating the sustainability of the products we sell at CVS Pharmacy and increasing the availability of sustainable products more broadly,“ said Eileen Howard Boone, senior vice president of corporate social responsibility and philanthropy at CVS Health in an article in greenBiz.

The retail companies noted here hope that other companies will follow their lead, especially companies that are more active in e-commerce business. TSC wants to use 2018 as a year of continuous development of the rating system, says TSC’s CEO, Euan Murray.

Ensure the legal compliance of your products. If you have any questions, you can contact us at cosmetic@kft.de.

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U.S. Guidelines for Hazard Communication to Be Aligned with GHS Guidelines

The U.S. Occupational Safety and Health Administration (OSHA) plans to revise its Hazard Communication Standard (HCS) in 2019 and align it with the Globally Harmonized System (GHS) of classification and labelling of chemicals of the United Nations.

The United States Department of Labor (DOL) (United States Department of Labor, DOL) decided on the change this Spring as part of its regulatory agenda, moving the project from a status of “long-term action” to that of a “proposed rule.”

OSHA last revised the Standard in 2012, when it aligned with the third revision of the GHS. The seventh revision has been in force in July 2017 and can be downloaded from the UNECE-Website. The compendium will be updated next year.

An important goal of OSHA is to align the Standard with the Canadian and EU approaches to the GHS. Maureen Ruskin, deputy director – directorate of standards and guidance, provided more information in a presentation she gave in March this year.

The UN Sub-Committee of Experts on the Globally Harmonized System of Classification and Labelling of Chemicals (UNSCEGHS) will hold its 35th meeting from July 4 – July 6 in Geneva. The positions to be taken by and the suggestions to be made by the U.S. representatives at the meeting will be worked out in a public meeting on June 12 at the Department of Transportation in Washington, D.C.

Do you need support to follow the GHS Guidelines in your country? We are here for you at sds@kft.de.

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GHS: Why Regulations Aren’t Uniform

In his overview article in CHEManager (German only), KFT director Karl-Franz Torges discusses why no real uniformity exists after 15 years of GHS – even though the United Nations Conference on Environment and Development (UNCED) held in Rio de Janeiro (The Earth Summit) in 1992 decided on harmonization of the classification and labeling of chemicals.

Yes, GHS has already been implemented in 50 countries. But in highly various ways and no GHS regulations yet exist in 128 countries. Torges identifies some important reasons for the discrepancy. The undesirable multiplicity of approaches arises partly because individual countries introduce GHS based on various revisions of the system. Other countries select individual parts of GHS and implement those in their national laws and regulations, a building-block approach. Torges, an expert in chemical compliance, also covers the situation with safety data sheets, which is no less complex than GHS.

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

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U.S. EPA Bans Methylene Chloride from Paint Strippers

The U.S. Environmental Protection Agency (EPA) has suggested prohibiting the production and use by private persons of paint strippers that contain methylene chloride (also called dichloromethane) and has drafted a corresponding regulation under Section 6 of the Toxic Substances Control Act (TSCA). The agency will soon send the draft to the Office of Management and Budget (OMB), as indicated in its press release.

 Methylene chloride is an outstanding solvent for resins, fats, plastics, and asphalt. It can also serve as a paint stripper and a degreasing agent. Nevertheless, the dangers of the substance have been known for some time. Workers exposed to the substance have a higher risk of contracting cancer and liver disease. That’s why the administration of President Obama proposed an appropriate rule, but its approval has been delayed.

 After recent deaths caused by use of methylene chloride, NGOs began campaigns and called upon building supply stores to stop selling paint strippers that contain methylene chloride. They were successful. Just two days after a meeting of EPA director Scott Pruitt with NGO members and the families of those who died from
illnesses related to methylene chloride, the EPA decided to act. It stopped plans for a reevaluation of
methylene chloride as originally requested by representatives of the Halogenated Solvents Industry Alliance (HSIA).

In the EU, the use of methylene chloride in paint strippers by private persons and commercial entities
is forbidden by
Decision 455/2009/EC of the European Parliament as of May 6, 2009. Industrial uses are exceptions. Effective December 6, 2012, all paint strippers that contain methylene chloride and are used
industrially must be labeled accordingly.

 Do you deal with hazardous chemicals? Make sure you are compliant with all applicable laws and contact us at reach@kft.de.

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Canada: Stricter Limits for Lead and Cadmium in Children’s Products

The Canadian health ministry, Health Canada, has published two new regulations: Children’s Jewellery
Regulations: SOR/2018-82
) and the Consumer Products Containing Lead Regulations: SOR/2018-83. Both take effect six months after publication in the Canada Gazette.

The Children’s Jewellery Regulation states that the following products may contain a maximum of 90 mg/kg of lead.

  • Toys intended for children between 3 and 14 years of age
  • Children’s clothing and accessories
  • Products primarily intended to facilitate the relaxation, sleep, hygiene, and transportation of a child less than four years of age

The same regulation also defines a total permissible amount of cadmium of 130 mg/kg in children’s jewelry that is small enough to be swallowed and a total permissible amount of lead of 90 mg/kg (previously set at 600 mg/kg and 90 mg/kg for migratable lead).

Two non-governmental agencies active in health matters find the definitions wanting. They are calling for limits that apply to jewelry in general, not just children’s jewelry. After all, they point out, children also have access to adult jewelry.

In Germany, the definitions set by REACH apply: Up to 0.01% by weight for cadmium and up to 0.05% by weight for lead. Cases involving costume jewelry that exceed those limits are not rare. For example, as part of a study, the Regional Council of Tübingen found that 10% of jewelry items in floor trading had an
increased level of lead and or cadmium. Some 17% of jewelry items sold on the Internet, had levels that
exceeded the legal limits.

We can help you ensure the legal compliance of your products. Please contact us at reach@kft.de.

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EU Publishes 11th ATP for the CLP Regulation

The EU Commission has issued Regulation (EU) 2018/669, the eleventh amendment of the CLP Regulation (EC) No. 1272/2008, an adaptation to technical and scientific progress (ATP). The new regulation takes
effect on May 24. The transition period will end on December 1, 2019. It gives suppliers an opportunity to adjust the labeling and packaging of chemicals and mixtures appropriately.

The amendment affects Table 3, “list of harmonized classification and labelling of hazardous substances” in Part 3 of Annex VI of the CLP Regulation. Thus, the chemical names are available in the individual languages of the member states. The chemical names on the label and in the individual parts of the safety data sheets will have to be written in the respective national language.

The amendment does not add any new substances, and the classification of substances remains unchanged.

The EU published the tenth amendment in May 2017. Please see our blog entry, CLP: Tenth Adaptation to Technical and Scientific Progress Published.

If you have any questions on this topic, please contact us at clp-info@kft.de.

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WHO: Styrene Probably Carcinogenic

The International Agency for Research on Cancer (IARC), an agency of the World Health Organization (WHO) headquartered in Lyon, France, has classified styrene, styrene-6,8-oxide, and quinoline as probably carcinogenic (2A). The agency had previously classified styrene as possibly carcinogenic (2B). The higher classification has consequences for entities and countries that use the IARC as a standard for regulations, as is the case in California.

The new classification is based on a study that appeared in April in the journal The Lancet Oncology. According to the study, workers who manufacture reinforced plastics and thereby come into contact with styrene are more likely to suffer from lymphohaematopoietic malignancies. The authors of the study
therefore regard it as valid proof that exposure to styrene leads to this type of cancer. Nevertheless, they admit that the influence of confounding, bias, or chance cannot be completely excluded.

However, the knowledge gained to date from animal experiments is unambiguous. Researchers conclude that the mechanisms in animals and humans are the same and that the substance has genotoxic effects.

According to the journal Procedia Engineering, about 20 million tons of styrene were produced in 2012. More than half of that amount is processed into polystyrene. Quinoline is an ingredient in the manufacture of medicine and dyes. Styrene oxide is used to manufacture epoxy resins.

The American Chemistry Council (ACC) criticized the classification of styrene. It is incomprehensible because the study is based on outdated rules that are now being revised by experts, says Cal Dooley, president and CEO of the ACC. He also questions the timing of the publication, given that the IARC will have a new director at the beginning of 2019, who may well focus on completely different questions.

We are always pleased to advise you on the marketability of your products. You can reach us at reach@kft.de.

 

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