Chemical compliance

What’s happening? Here is an update for November 2023:

Poison Centre Notifications: second compliance date
PFAS: EPA finalises reporting rule

Poison Centre Notifications: second compliance date

The second compliance date for Poison Centre Notifications (PCNs) is 1 January 2024, and concerns industrial use only mixtures.

These are mixtures which are used exclusively at industrial sites and are not available to consumer or professional users, either as a final product or in diluted form through reformulation.

The PCN requirement for any other mixtures (for consumers and professional users outside industrial sites) is already in force, so any mixtures that haven’t been notified yet should undergo the process by the end of this year.

The PCN requirement applies to European importers and downstream users.

The Hazard Communication team at Landbell Group company, H2 Compliance is preparing a more detailed article on this topic for the next COMPASS.

In the meantime, please get in contact for more information.

PFAS: EPA finalises reporting rule

In October, the US Environmental Protection Agency (EPA) finalised their long-awaited per- and polyfluoroalkyl substances (PFAS) reporting rule.

The rule requires PFAS manufacturers and importers to report on the type and quantity of these compounds manufactured or imported in any year from 1^st January 2011, until present. The reporting rule also extends to article (products) importers.

The sweeping rule aims to acquire information on PFAS usage in the United States and is a critical element of the Bien-Haris PFAS action plan, as well as the EPA’s strategic PFAS roadmap.

Companies obligated to report on PFAS must do so within 18 months of the effective date of the ruling (30 days after publication in the Federal Register). Article importers have an extended deadline of 24 months.

While details have not been finalised, there will be an electronic submission method to report on PFAS. A streamlined submission protocol will also be available for importers of articles.

Manufacturers and importers will need to provide information on the type, quantity, uses, exposures and disposal methods of PFAS substances. Exposure criteria must include information on frequency and duration of use for exposed individuals. Existing information on the health effects of each substance is also being requested.

The EPA’s reporting rule comes at a time when several US States also have their own reporting measures. Rules in Maine as well as proposed rules in Minnesota require manufacturers to disclose similar information.