Proposed new CLP hazard classes from the EU, 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:

https://ec.europa.eu/growth/tools-databases/tbt/en/search/?tbtaction=search.detail&Country_ID=EU&num=915&dspLang=en&basdatedeb=&basdatefin=&baspays=&basnotifnum=&basnotifnum2=&baskeywords=1272%2F2008&bastypepays=ANY&baskeywords=1272%2F2008

and

https://ec.europa.eu/growth/tools-databases/tbt/en/search/?tbtaction=search.detail&Country_ID=EU&num=905&dspLang=en&basdatedeb=&basdatefin=&baspays=&basnotifnum=&basnotifnum2=&baskeywords=1272%2F2008&bastypepays=ANY&baskeywords=1272%2F2008

Video 1 covers PBT/vPvB and PMT, vPvM

Transcript Proposed new EU hazard classes PBT and PMT 2022-09-21

Download the transcript (PDF)

TLDR:

  • 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)

TLDR:

  • 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