About Poison Centre Notification
CLP Article 45 provides for each Member State of the EU to appoint bodies responsible to hold information on hazardous mixtures imported or made in the EU, for the purposes of providing a central contact point in an emergency for users such as medical professionals and/or the general public. This continues the process started under the Dangerous Preparation Directive in 1999.
These bodies are called Poison Centres, and notification to them has been very variable across the EU: different countries have required different levels of information; some countries have charged fees; and there has been the requirement to notify to individual Poison Centres in each country.
This situation has been clarified by the introduction, in 2017, with the introduction of Regulation EU 2017/52, which amends CLP by adding Annex VIII on harmonised information relating to emergency health response, see Annex VIII to CLP March 2017 .
This amending regulation explicitly places a duty on formulators and importers to report their mixtures’ properties to the Poison Centres, which was previously only implicit within CLP, and which therefore may have been ignored by some companies.
It defines a timescale for the introduction of harmonised reporting to the Poison Centres, depending on whether a mixture is for consumer (2020), professional (2021) or industrial use (2024), and also lists what information should be submitted.
More information will be required for consumer use, and less for industrial use, as it is recognised that most enquiries to Poison Centres are from consumer users and professionals, and comparatively few requests are from industrial users.
Each hazardous mixture (or group of related mixtures) will be given a Unique Formulation Identifier, UFI, which is to be generated by the supplier using an electronic system at ECHA. The UFI is to be listed on the label and on the SDS, and will be the same throughout the EU, in theory allowing the mixture to be identified more quickly in an emergency.
Overall, although this amending regulation is a step forward in ensuring a more harmonised system for Poison Centre notification in the EU than currently exists, it still has several drawbacks:
- there is no central submission point for mixture information, companies will still need to submit an application to each individual member state where they are selling their mixture (although at the time of writing, July 2017, ECHA are considering whether a portal can be set up to allow single submission)
- individual member states can charge for this process, and the fees vary
- it is understood that individual member states can request information above the minimum requirements in the amending regulation
- individual member states use different software systems for their notification, and these can vary wildly
- individual member states are likely to require notification in their own language
Poison Centre notification is an extra burden on formulators and importers of mixtures, and it will be interesting to see whether the system works as intended, and what improvements are made in helping end users of mixtures during an incident.