ECHA Reveals 90,000 Chemicals

The European Chemicals Agency (ECHA) has launched the Public Classification and Labeling (C&L) Inventory database.  Quite notably, this is the world’s largest database of self-classified chemical-substance data. Information in the database is threshed from REACH registrations and CLP notifications so far received by the Agency.

The public can freely browse or search the C&L Inventory now: http://echa.europa.eu/web/guest/information-on-chemicals/cl-inventory-database

But first a warning: in these first days of the new database tool, it’s recommended you begin by searching on a few chemicals you are very familiar with. This will give you a feel for the accuracy of search returns.

Another warning:  be alert to multiple and inaccurate chemical classifications.  For more on that and how errors happen, see details at asterisk at bottom, below the database preview.*

References for further reading, courtesy of REACHspot:

  1.     Public C&L Inventory: http://echa.europa.eu/information-on-chemicals/cl-inventory
  2.     C&L Inventory Factsheet: http://echa.europa.eu/documents/10162/17242/factsheet_public_classification_labeling_en.pdf

Preview:

CL Inventory database CLP REACH 90 000 chemicals

You’ll notice the chemical inventory database is searchable by 1)substance identity or 2)substance classification.  ECHA says it expects to improve search functions — so if C&L searches seem unreliable at first, continue to check back with the database, and by all means continue to send notes to ECHA stating how helpful improved search capability would be (so their IT department can prioritize).

The Inventory is maintained by ECHA and the data will be refreshed on a regular basis with incoming and updated C&L information.

The C&L Inventory database and CLP and REACH  So you may be wondering, how does it all connect?  The C&L Inventory is a database which contains classification and labeling information on substances notified under Regulation (EC) No 1272/2008 — known as the CLP Regulation — and registered under Regulation (EC) No 1907/2006 (the REACH Regulation).  Plus, it will also contain the list of legally binding harmonized classifications (Annex VI to the CLP Regulation).

The C&L Inventory database aspires to serve multiple purposes:

  1. It is a tool for hazard communication and a source of basic information on substances placed on the market which meet the criteria for classification as hazardous or are subject to registration, for suppliers of substances, the general public and Member State Competent Authorities (MSCAs)
  2. It reveals differences in the classification and labeling of the same substance applied by different suppliers, thus pointing to the need for further discussion among companies to explore the reasons for differences and/or agree the most correct classification, evaluation needs or the need for a legally binding harmonization of a particular classification and labelling of a substance
  3. It is an important tool for hazard communication and risk management, e.g. when MSCAs assess the need for potential authorizations and restrictions of hazardous substances under REACH

Asterisk * Different classifications within C&L Inventory

ECHA says a primary goal of the C&L Inventory is to promote uniform classification of substances.  However…

However, for many substances different classifications will have been notified.  Over time this will be corrected.

Some instances of multiple or inaccurate classifications can be explained by technical errors made during the notification process (e.g. not assigning all labeling elements correctly) or slight differences in seemingly identical notifications (e.g. affected organs or route of exposure differs). However, different notifiers can also disagree on the classification of a substance based on different interpretation of scientific studies or different access to those studies.

In any case, notifiers have the legal obligation to make every effort to come to an agreed entry to be included in the inventory and inform ECHA accordingly.  (See Article 41 of the CLP Regulation, which says “each SIEF should agree on classification and labelling where there is a difference in the classification and labeling of the substance between potential registrants”…and again…. “the notifiers and registrants shall make every effort to come to an agreed entry to be included in the inventory.”)

Additionally, sometimes there are different (legitimate) reasons for why notifications for the same substance have different classifications. Different compositions or impurity profiles often lead to different classifications.  Also, of course, the physical state and form of a substance is often very important when the hazards of a substance are assessed. The Public C&L Inventory displays the notified state and form but does not contain any information on composition or impurities.

And finally, technical errors made when notifying to the C&L Inventory can also lead to different classifications assignments that are inauthentic.

For awhile, these quirks will be “fair enough,” but over time they must be ironed out.  Else, there is little use in having a database at all.  Time will tell.  The potential is there, though, for a truly remarkable public tool to help solve the challenges of the chemicals in our modern world.

 

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About Kal

Kal Kawar, CIH, PE, has a bachelor's in chemical engineering and a master's in industrial hygiene. His professional experience includes serving as staff industrial hygienist for IBM's New York semiconductor manufacturing facility, and as industrial hygienist for IBM’s US headquarters. Now executive vice president of Actio, Kal taps more than 20 years' worth of chemical engineering, industrial hygiene, and environmental engineering experience. His far-reaching expertise with global regulatory challenges created by EPA, TSCA, REACH, RoHS, WEEE – and hundreds of others – aid in developing Actio software solutions for MSDS management, raw material disclosure compliance, and product stewardship in a supply chain.