I use fragrances to make air fresheners or candles, how do I keep the Formpak system up to date so I can be compliant with CLP?
There isn’t a single source for updates, and it goes beyond the software also. The key source of data is your suppliers (of raw materials and fragrances). When you have updated information about hazards or compositions of your ingredients you need to make changes ‘without undue delay’ and supply information onwards in the supply chain (typically via labels and SDS). The key things which need to be monitored are:
- The CLP rules – Formpak keeps these up to date from a calculation viewpoint, but you need to stay aware of other areas in order to be ‘compliant’ e.g. requirement to notify to the C&L inventory, requirements around packaging etc. Usually trade associations help their members stay up to date in this area.
- The raw material hazard classifications – the key source of data should be your product suppliers/providers. Formpak can assist annually with the fragrance chemicals which are notified to IFRA members. We can do this via a matching process which you need to review and it can provide a convenient annual update for most of your aromachemicals (you may want to consider becoming an IFRA member). Please note this data, provided by the fragrance industry, reflects a point in time and in reality raw material classifications change throughout the year and key changes should be notified to you by your suppliers (it is a key legal responsibility that suppliers do this). You need to keep all your ingredients up to date, not just fragrance ingredients, and you need to take steps to do this. There are some external data sources, some paid for, some free, but nowhere lists everything and judgement is often necessary.
- The compositions of any complex raw materials, such as fragrances are required to be kept up to date as this can affect hazard labelling and SDS. The fragrance composition data is only available through your supplier.
We hope this is helpful general information. You can additionally refer to the CLP regulation for the legal text which gives all of the rules.