By the end of last year, Trace One GmbH started roll-out of the UFI/PCN module for fulfilling the requirements according to Annex VIII CLP regulation. Other new functions and updates of the HSM software are in the pipeline, especially with respect to the Regulation (EU) 2019/1148 (explosives precursors) listing evaluation, the classification of Titanium dioxide according to ATP 14 CLP Regulation and the new Safety Data Sheet requirements according to the revised Annex II of the REACH Regulation.
HSM Poison Centre Notification Module: The roll-out began already last year, feedback from our customers was very positive, especially from those who already could successfully submit notifications by using the S2S functions. In these customer projects, Trace One GmbH provides consultancy and support, e.g. with respect to better integration in the customers’ workflow, installation patches for last minute changes of the ECHA format and issuing enhancements like e.g. for the collecting and managing ECHA feedback after PCN submissions.
Explosive precursors: New regulation what and when
The new Regulation (EU) 2019/1148 (Explosives precursors) will apply from 1 February 2021. It establishes new requirements for distributors of certain substances (as such or in mixtures), e.g. verification of buyers and transactions, communication in the supply chain and reporting to relevant authorities. The said substances, listed in two annexes (which may be extended in the future by delegated acts), are substances which could be misused for the illicit manufacture of explosives. The annexes not only contain strong oxidizers, nitrification agents etc. but also substances like acetone having widespread use in various kinds of mixtures (and can form an explosive after reaction with higher concentrated hydrogen peroxide - which is also on that list).
HSM is about to provide a new property for assigning a basic substance to the explosives precursors list, a new evaluation calculation for mixtures and a design extension for the output of corresponding information on the SDS.
Regulation (EU) 2020/217, known as ATP 14, shall apply from 9 September 2021. The corresponding update of Annex VI is available for some time. TiO2 was already in the Prosisoft substance inventory because of its presence in several national workplace exposure lists. For the classified version of TiO2 (in powder form containing 1 % or more of particles with aerodynamic diameter ≤ 10 μm) we introduced a new substance entry.
We are now about to extend the CLP classification calculation of mixtures by a new calculation rule.
New SDS requirements
Regulation (EU) 2020/878 amending Annex II of the REACH Regulation (Safety Data Sheet) establishes new requirements (changes of Section 3, 9, 11, specific changes for nano forms and endocrine disrupting properties etc.) for the SDS.
Trace One GmbH will start the implementation in the first half of this year 2021.