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Communicating chemical hazard and risk information to consumers ...

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Communicating chemical hazard and risk information to consumers ...

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    1. Communicating chemical hazard and risk information to consumers – A Member State view Dr Robin Foster International Chemicals Unit Health & Safety Executive 4th AISE Information Day, 28 November 2007

    3. Chemical products supplied to the public

    4. Approaches to regulating marketing of chemicals Authorisation / licensing / approval Highest level regulatory intervention All prohibited unless regulator allows Regulator does risk assessment Expensive! Positive listing of components Regulator allows certain ingredients only Registration Inform regulator what is marketed No marketing restrictions

    5. Communicating information Product labels Hazard, risk, directions for use, safety precautions Safety data sheets Usually for use at work Available to public on request Other means Package inserts internet

    6. PPPs and Biocides Product-by-product approval system Nothing allowed unless regulator agrees Covers all PPPs and biocides, inc. those for consumers Regulator does risk assessment based on huge data sets Health, safety, environment, efficacy Expensive! Uses prescribed – conditions of use imposed Extensive labels include detailed information on hazard, risk, conditions for use

    7. Biocide Label Example

    8. Biocide Label Example

    9. Biocide Label Example

    10. Medicines Product-by-product approval system Nothing allowed unless regulator agrees Covers all medicines, including ‘self-prescribed’ Regulator does risk assessment based on huge data sets Health, efficacy Expensive! Uses prescribed Presumption of benefit – generally intervention by doctor Extensive labels / inserts with detailed information on risk, conditions for use

    11. Medicines - example

    13. Cosmetics Bans/Positive listing of certain ingredients system Regulator specifies ingredients and any conditions No other marketing restrictions Consumer safety only Regulator does limited risk assessment Relevant health effects Less expensive system than medicines, PPPs, biocides Uses not prescribed Limited hazard and risk information on product labels

    14. Cosmetics - example

    16. Foods Bans/Positive listing only for few ingredients, eg additives No other marketing restrictions For these ingredients, regulator does risk assessment Relevant health effects Relatively cheap for industry Uses not prescribed Presumption of ‘wholesomeness’ Requirements for hygiene in preparation and use Extensive labelling - ingredients, nutritional value, cooking instructions, ‘use by’, etc

    17. General chemicals REACH registration of ingredients (substances) Regulator can intervene selectively, eg for substances of very high concern (SVHC) Full coverage - workers and consumers Mostly industry does risk assessment Safety, health, environment Uses generally not prescribed by regulators Dialogue between suppliers & users Exception for SVHC Hazard and risk information on product labels Existing EU system; in future GHS

    18. General Chemical - example

    20. General points (1) Regulators want users to have information about all potential harms, even if risk low – ‘right to know’ Foreseeable use Foreseeable misuse Accident situations Favour integrated schemes for all users (h/s/env; consumers & workers) Boundary between consumer and worker increasingly ‘fuzzy’ Difficult to justify different standards

    21. General points (2) Overall picture rationalising with REACH, but still compartmentalised. However, Hazard and risk information unless additional safeguards and presumption of Professional individual oversight (medicines) Wholesomeness (cosmetics, food) Regulators sometimes overlook Comprehensibility / practicability of information AISE work helpful

    22. Observations on AISE approach to GHS (1) GHS is a hazard based system GHS agreed on basis that doesn’t directly force jurisdictions to change existing approaches Annex V included for US (and for chronic consumer health hazards only)

    23. Observations on AISE approach to GHS (2) Does the scheme AISE propose Justify different information requirements in different circumstances? Consumers vs workers Health hazards vs safety / env hazards? Cover foreseeable misuse? Respect existing EU values and standards?

    24. Ways forward Alternative approaches Seek to amend hazard classification criteria at UN level? Ask whether EU should adopt UN GHS skin corrosion / irritation building block now? Use existing flexibilities in GHS for mixtures? [Needs data, preferably generated in validated in vitro test methods]

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