An excel based list of changes to New Formpak is available in the Downloads area; you must be logged in to see it. It includes the Formpak build number, date and brief description of the changes. Downloads can be found by clicking on SUPPORT page of the blog and selecting ‘Downloads’.
We’ll maintain the list and update it on the blog regularly.
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Environmentally Hazardous for transport has been based on GHS criteria for some time now with a product classification of Environmental Hazard Chronic Category 1 or 2, or Acute Category 1 meaning the product is environmentally hazardous for transport: Class 9 (if not meeting other transport hazard criteria which overides or modifies this Class).
In most cases the terms Marine Pollutant and Environmentally Hazardous are used interchangeably (which can be a bit confusing!). There is one specific area of difference to draw attention to. It’s a hang over from previous regulation in the IMDG code relating to substances marked with ‘P’ in Annex III of Marpol. Such substances are also considered to be environmentally hazardous for transport, even if they do not meet GHS criteria of EH C1, EH C2 or EH A1. The list of materials is no longer being extended and, with approval of the competent authority, substances which no longer meet the criteria for environmentally hazardous but remain on the list need not be transported as marine pollutants.
The change to Formpak transport classification methods for mixtures is that the assignment of phrase ‘MP’ = Marine Pollutant to ingredients of the mixture will no longer impact the transport classification of a mixture (previously >10% of MP caused a classification of environmentally hazardous). However, if ‘MP’ is assigned to a substance, it will still impact the transport classification in the way it always has which is to make the substance Environmentally Hazardous for transport.
GHS is updated from time to time and this impacts national legislation like CLP. The 2nd ATP of CLP, prompted by 3rd Edition of GHS, has been implemented into European Law with REGULATION (EU) No 286/2011 and comes into effect on 1 December 2012, with transitional provisions allowing later implementation (please consult the regulation for more details)
In response to this, properties and calculations have been added or modified in Formpak:
Sensitisers: The regulation now includes additional categories of skin and respiratory sensitizers. Previously, CLP had just Category 1 and now there is also Category 1A (strong sensitisers) and Category 1B (other sensitisers). Category 1 remains valid and is used when there is insufficient data to sub categorise.
The calculation for sensitisers has been changed to reflect the lower trigger levels for Category 1A substances in mixtures (they trigger lower level labelling / sensitising classification at 0.01/0.1% which is ten times lower than Category 1 and Category 1B).
In addition, lower level sensitisers are now to be labelled even when the whole product is classified as a sensitiser, so this has been adjusted.
Supply of ‘Professional Use’ Safety Data Sheets
There was a change to the circumstances when EUH 210 ‘Safety Data Sheet available on request’ should be given on a label and this has been updated.
Hazardous to the Ozone Layer
Previously this regulation gave a European supplemental phrase of EUH 059, Hazardous to the Ozone Layer. This changes to a GHS statement of H420: Harms public health and the environment by destroying ozone in the upper atmosphere; the criteria for assignment of this hazard to a substance changes; the 0.1% trigger for assignment to a mixture is 0.1% (the same as it was for assigning EUH 059). H420 carries the ‘Warning’ signal word and EUH 059 carries ‘Danger’.
Please note: we do not make changes to individual item properties, so if you have any materials which are affected by these classification changes you may need to modify the properties which are assigned.
There are other changes in the legislation e.g. relating to classifications of environmentally hazardous for substances, so please refer to the regulation for a more complete picture.
Safety Data Sheet
We have made some minor improvements to the Safety Data Sheet in Section 2: a) In section 2.1, R phrases are now shown; b) In Section 2.2, precautionary statements now appear for raw materials (Annex II SDS) ; c) In Section 2.2 duplicated label information is removed
If you have any questions, please contact us.
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Project Management is now available on New Formpak. Project templates are customisable to enable you to reflect your processes and include any kind of project within your system. In addition to traditional product based projects, you could add marketing projects and technical projects for example. The Project Management system is introduced on the following videos:
http://www.youtube.com/watch?v=nLBV55ney9s
https://www.youtube.com/watch?v=3eUepy1wr1A
As always, if you would like any further information, please contact us.
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Formpak Software can generate many kinds of documents, track and manage changes to data in them, provide document traceability and trigger resupply. In addition to documents such as Safety Data Sheets and Labels, Formpak can produce status documents for IFRA, Allergens, Food Allergens, Nutritional Information and also complex Specifications.
New documents can be designed and existing ones can be customised. For more information about documents, including cost indications for customisation, download the Document Customisation (1)information. Please note you must be logged in to download the pdf file.
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