Hazardous substances in encapsulated pellet/solid form
  • A Chemical WatcherA Chemical Watcher
    If hazardous substances are encapsulated in a pellet/solid form, is the final product considered as hazardous under CLP/EU?
  • Jennifer LambJennifer Lamb

    This is slightly dodgy ground and something we as masterbatch producers have been discussing for months.


    There is an exemption under CLP that states the following:


     


    "


    “1.3.4.           Metals in massive form, alloys, mixtures containing polymers, mixtures containing elastomers<?xml:namespace prefix = o ns = "urn:schemas-microsoft-com:office:office" />


    1.3.4.1.         Metals in massive form, alloys, mixtures containing polymers and mixtures containing elastomers do not require a label according to this Annex, if they do not present a hazard to human health by inhalation, ingestion or contact with skin or to the aquatic environment in the form


    in which they are placed on the market, although classified as hazardous in accordance with the criteria of this Annex.


    1.3.4.2.         Instead, the supplier shall provide the information to downstream users or distributors by means of the SDS.”


    So... the SDS must have the relevant hazard information on but the label on the packaging can be left without. I have been advised that to leave it off the packaging it is best to have a toxicologist confirm this stance.

  • Margareth KoppesMargareth Koppes

    Hi, we are a masterbatch producer and finding out confirmation on the information needed on the SDS and the label on the packaging of our masterbatches. Which of the classified substances and how many should you mention on the SDS if the product is encapsulated/ in pellet/ solid form?


    Some of our substances we are using in the masterbatch are known to migrate to the surface of the pellets?


      

  • Ian SawyerIan Sawyer

    The exemption referred to (1.3.4) relates only to labelling;  "see Section 1.3 Derogations from labelling requirements for special cases".


    In my opinion, you would need to be very confident that the substance "did not present a hazard" before applying that derogation.  The assessement would need to consider all use scenarios.


    Either way, it does not affect the hazard classification.


     

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