European Poison Centre Notification Deadline: Limited Submission for Industrial Mixtures
With the New Year approaching, the January 1, 2024 deadline for the submission of poison centre information in the new CLP Annex VIII format for industrial mixtures might seem far away, but it is a good time for organizations to make sure that they have plans in place to meet the deadline.
A product is considered to be an industrial mixture if it is used only in industrial applications. If a mixture is formulated into another mixture for professional or consumer uses, even if this happens several steps down the supply chain, then it must be notified as a professional or consumer mixture as appropriate-for which this deadline was January 1, 2021.
There are two options for the submission of information on industrial mixtures:
- Full submission
- Limited submission, provided that additional product information can be provided rapidly in case of a health emergency
The limited submission option allows companies to provide only the information on the composition of the mixture that would normally be included on a Safety Data Sheet, allowing them to better protect their confidential information. However, to take advantage of this option, companies need to be able to rapidly provide additional information by telephone or email if requested in a health emergency. This service needs to be available 24/7, and the company must be able to provide the information in the language of the Member State where the mixture is placed on the market, unless the Member State has provided otherwise (see here for a list of countries and languages that they accept).
The CLP regulation does not define what it means by rapid access to additional information, but it could be expected that regulators would take into consideration other standards for provision of emergency information in a chemical incident when deciding what could be considered reasonable. For example, the CEFIC ICE scheme, which sets standards for responding to transport incidents, requires callers to be connected to an emergency response expert (including an interpreter if needed) within 3-5 minutes, initial advice to be provided within 10 minutes, and further detailed follow up, if needed, within 30 minutes.
If companies are not able to provide a suitable emergency number and response themselves, they can either make a full poison centre notification, or contract out the provision of additional rapid advice to a suitable organizations such as CHEMTREC who have 24/7 access to local phone numbers, interpreter services and medical professionals who can either handle the call or support the relevant Poison Centre.