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Download the PDF for PBT/vPvBPMT_vPvM Infographic V5.2
Download the PDF for PMT/vPvMInfographic Human Health V5.3
Download the PDF for Human Health Endocrine DisruptorsInfographic-ENV V5.3
Download the PDF for Environmental Endocrine Disruptors
6th April 2023: some changes to infographics appearance to make them clearer.
5th April 2023: we finally worked out that the infographics which were uploaded in January were draft and not the final version – oops! Many thanks to Steve Marks of Airedale Chemicals. The infographics below have been triple-checked and are definitely correct now, apologies for any confusion.
4th April 2023; we have just updated the PMT/vPvM infographic to correct typos in the “substance classification mobile” table (briefly, they were the wrong way round). Many thanks to Sergii Lytvynenko of Juul Labs for spotting this and letting us know.
31st March 2023: the EC have published the new hazard classes in the European Journal today: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32023R0707&qid=1680271109506 .
Update, 3pm – the consultation which closed yesterday is for the Legislative Act, which amends the CLP articles to include the new hazard classes.
Today’s publication is the Delegated Act, which was agreed on 19th December, which amends the Annexes to CLP to bring in the details of the hazard classes.
It’s very confusing, but means that the current consultation is within time.
The good news is that it means the infographics are correct.
January 2023: we’ve updated the infographics on the new hazard classes (tentative, as the rules may still change)
December 2022: a new set of proposals has been issued by the EU, you can find them here:
The updated proposals are here: https://environment.ec.europa.eu/publications/proposal-clp-revision_en
and the actual draft regulation and ATP are available here: https://environment.ec.europa.eu/publications/clp-delegated-act_en
September 2022: We’ve made a couple of videos going through the draft proposal from the EU on new hazard classes.
You can find the EC proposals here:
Video 1 covers PBT/vPvB and PMT, vPvM
Transcript Proposed new EU hazard classes PBT and PMT 2022-09-21
Download the transcript (PDF)
- PBT/vPvB comes from REACH; PMT/vPvM comes from plant protection products/ biocidal products regulation
- these are called EUH statements but are being proposed to be brought into CLP in the same sections as H statements
- at the same time as bringing them into EU-CLP, the EU have taken these new hazard statements (also including endocrine disruptors) to the UNECE GHS committee and are trying to get them adopted as GHS hazards
- the classification methods are relatively straightforward
- bridging principles are absent, which is a bit anomalous
- the new classifications bring in signal words and P statements, but not new pictograms
- the absence of pictograms may be to avoid interfering with Transport of Dangerous Goods classifications
Video 2 covers Endocrine Disruptors
Transcript Proposed new EU hazard classes endocrine disruptors 2022-09-21
Download the transcript (PDF)
- Endocrine disruptors classification for substances is are not as clear-cut in as the new PBT and PMT classifications discussed in the first video
- these are also called EUH statements but are being proposed to be brought into CLP in the same sections as H statements
- bridging principles are present for mixtures
- the new Endocrine Disruptor classifications bring in signal words and P statements, but not new pictograms
- to be classified as ED, 3 tests must be passed, (a) Endocrine activity and (b) An adverse effect and (c) A biologically plausible link between (a) and (b).
- the “biologically plausible link” definition includes correlation, leaving it open to interpretation by toxicologists
- there is a lot of overlap between existing STOT classifications and proposed ED classifications
- extra testing may be required to differentiate between STOT and ED, but is there appetite for more animal testing?
- remember this is all at proposal level, so feed back concerns to ECHA
- do not take any classification actions or decisions until the regulation is actually published, as there may be alterations to the draft –
- even if these are brought into the EU, there are very long implementation times
- and they may not be brought into the UK at all, or if they are it is likely to be “downstream” of, and therefore later than in the EU