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Regulating chemical testing, evaluation with REACH

October 1, 2009

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Although the Globally Harmonized System for the Classification and Labeling of Chemicals is intended to reduce a need for duplicate testing and evaluation, it does not include requirements for testing substances or mixtures.

According to OSHA’s comparison of hazard communication requirements with GHS, “there is no requirement under the GHS to generate test data for any hazard class. Some parts of regulatory systems may require data to be generated (e.g., for pesticides), but these requirements are not related specifically to the GHS. The GHS criteria for determining health and environmental hazards are test method neutral, allowing different approaches as long as they are scientifically sound and validated according to international procedures and criteria already referred to in existing systems.”

In June 2007, a European Community Regulation on chemicals went into effect to govern safe use through registration, evaluation, authorization and restriction of chemical substances.

According to the United Nations Economic Commission for Europe, the goal of REACH is to “improve the protection of human health and the environment through the better and earlier identification of the intrinsic properties of chemical substances.” The effectiveness of REACH will improve as more chemicals are phased into the database system run by the European Chemicals Agency in Helsinki, Finland.

OSHA advises that “test data already generated for the classification of chemicals under existing systems should be accepted when classifying these chemicals under the GHS, thereby avoiding duplicative testing and the unnecessary use of test animals. The GHS physical hazard criteria are linked to specific test methods. It is assumed that mixtures will be tested for physical hazards.”

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