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Trace One
The 14th ATP of CLP
On February 18th 2020 Regulation (EU) n. 2020/217, corresponding to the 14th ATP, has been published on the official EU journal. This regulation amends Regulation 1272/2008 (CLP).
The 14th ATP updates annex VI of CLP by adding 17 new harmonised substances, deleting two and changing the classification of 12 substances already included in the annex.
Of the updated substances, the most controversial classification update regards the Titanium Dioxide (CAS: 13463–67–7), a substance widely used in paint products and many others which has now a classification as cancerogenous via inhalation of category 2 in the form of respirable particles. In order to avoid unjustified classification of non-hazardous forms of the substance, ATP 14th also provides specific notes for the classification and labelling of the substance and mixtures containing it.
New disposition: Titanium Dioxide
Two new EUH statements regarding products containing titanium dioxide are beign introduced:
- The label of liquid mixtures containing 1% or more of titanium dioxide particles with aerodynamic diameter equal to or below 10 μm will bear the EUH211 statement: “Warning! Hazardous respirable droplets may be formed when sprayed. Do not breathe spray or mist.”
- The label of solid mixtures containing 1 % or more of titanium dioxide will bear the EUH212 statement: “Warning! Hazardous respirable dust may be formed when used. Do not breathe dust.”
Furthermore, the following three new notes are beign added to Annex VI:
- “Note V: If the substance is to be placed on the market as fibres (with diameter < 3 μm, length > 5 μm and aspect ratio ≥ 3:1) or particles of the substance fulfilling the WHO fibre criteria or as particles with modified surface chemistry, their hazardous properties must be evaluated in accordance with Title II of this Regulation, to assess whether a higher category (Carc. 1B or 1A) and/or additional routes of exposure (oral or dermal) should be applied.”
- “Note W: It has been observed that the carcinogenic hazard of this substance arises when respirable dust is inhaled in quantities leading to significant impairment of particle clearance mechanisms in the lung.”
- “Note 10: The classification as a carcinogen by inhalation applies only to mixtures in powder form containing 1 % or more of titanium dioxide which is in the form of or incorporated in particles with aerodynamic diameter ≤ 10 μm.”
The 14th ATP will come into force on October 1st 2021, and can already be applied on a voluntary basis.
Trace One has planned a regulatory analysis and implementation of the 14th ATP, and will keep you updated on it.
Click this link to read the full text of the 14th ATP:
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