A Weight of Evidence approach to classify nanomaterials according to the EU Classification, Labelling and Packaging Regulation criteria

In the context of the European Union (EU) Horizon 2020 GRACIOUS project (Grouping, Read-Across, Characterisation and classification framework for regulatory risk assessment of manufactured nanomaterials and Safer design of nano-enabled products), we proposed a quantitative Weight of Evidence (WoE) approach for hazard classification of nanomaterials (NMs). This approach is based on the requirements of the European Regulation on Classification, Labelling and Packaging of Substances and Mixtures (the CLP regulation), which implements the United Nations' Globally Harmonized System of Classification and Labelling of Chemicals (UN GHS) in the European Union. The goal of this WoE methodology is to facilitate classification of NMs according to CLP criteria, following the decision trees defined in ECHA's CLP regulatory guidance. In the WoE, results from heterogeneous studies are weighted according to data quality and completeness criteria, integrated, and then evaluated by expert judgment to obtain a hazard classification, resulting in a coherent and justifiable methodology. Moreover, the probabilistic nature of the proposed approach enables highlighting the uncertainty in the analysis. The proposed methodology involves the following stages: (1) collection of data for different NMs related to the endpoint of interest: each study related to each NM is referred as a Line of Evidence (LoE); (2) computation of weighted scores for each LoE: each LoE is weighted by a score calculated based on data quality and completeness criteria defined in the GRACIOUS project; (3) comparison and integration of the weighed LoEs for each NM: A Monte Carlo resampling approach is adopted to quantitatively and probabilistically integrate the weighted evidence; and (4) assignment of each NM to a hazard class: according to the results, each NM is assigned to one of the classes defined by the CLP regulation. Furthermore, to facilitate the integration and the classification of the weighted LoEs, an online R tool was developed. Finally, the approach was tested against an endpoint relevant to CLP (Aquatic Toxicity) using data retrieved from the eNanoMapper database, results obtained were consistent to results in REACH registration dossiers and in recent literature.

Optimising testing strategies for classification of human health and environmental hazards - A proof-of-concept study

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Testing of chemicals does not always inform their subsequent risk management.

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Optimised testing strategies can improve efficiency of classification and labelling.

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Hazard pictograms were used to reflect the protection level for a given chemical.

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Two strategies led to the same protection level and required fewer tests.

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Another strategy led to the same protection level and reduced animal testing.

This paper outlines a new concept to optimise testing strategies for improving the efficiency of chemical testing for hazard-based risk management. While chemical classification based on standard checklists of information triggers risk management measures, the link is not one-to-one. Toxicity testing may be performed with no impact on the safe use of chemicals . Each hazard class and category is not assigned a unique pictogram and for the purpose of this proof-of-concept study, the level of concern for a chemical for the population and the environment is simplistically considered to be reflected by the hazard pictograms. Using active substances in biocides and plant protection products as a dataset, three testing strategies were built with the boundary condition that an optimal approach must indicate a given level of concern while requiring less testing (strategy B), prioritising new approach methodologies (strategy C) or combining the two considerations (strategy D). The implementation of the strategies B and D reduced the number of tests performed by 6.0% and 8.8%, respectively, while strategy C relied the least on in vivo methods. The intentionally simplistic approach to optimised testing strategies presented here could be used beyond the assessment of biocides and plant protection products to gain efficiencies in the safety assessment of other chemical groups, saving animals and making regulatory testing more time- and cost-efficient.

Is It Safe to Paint Your Wall White? A Case Study on Titanium Dioxide Classification

Titanium dioxide (TiO₂ ) is in the process of being classified as a suspected carcinogenic substance (Carc 2). The present case study probes the outcomes of this potential classification in terms of the reduction of hazardous exposure to TiO₂ due to its classification. Furthermore, the case study examines the elements that are causing ambiguity during the classification process. This study was conducted by walking through the process from the present exposure to TiO₂ to the hazard assessment associated with TiO₂ exposure, to the regulatory classification process, and to practical outcomes affecting TiO₂ usage. Finally, the impact of the classification on exposure, which was originally considered potentially hazardous, is evaluated. The case study shows that TiO₂ classification as a carcinogen will not directly reduce respiratory exposure to TiO₂ , which was the original reason for the classification. Instead, the classification will lead to restrictions on recycling. Moreover, the classification will have an impact on certain solid artifacts and liquid mixtures for which hazardous exposure was not detected. Altogether, the present case raises questions concerning hazard communications associated with the Carc 2 classification; treatment of poorly soluble low toxicity (PSLT) particles and nanoparticles in the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) and the Classification, Labelling and Packaging (CLP) classifications; and use of human exposure studies for the purposes of chemical regulations. Based on the present study, the following recommendations are made: the final decision on the TiO₂ classification should be reconsidered together with those of other PSLT particles and take into account extensive developments in the field of nanoscience. Furthermore, the European Chemicals Agency (ECHA) should develop state-of-the-art guidance on how to use the available human exposure data. Finally, the authorities that are in charge of European Union chemicals management are advised to further develop the regulatory network to utilize the information generated in REACH processes as efficiently as possible and to verify that the connections between the regulations result in the intended outcome. Integr Environ Assess Manag 2019;00:1-12. © 2019 SETAC.

New legal requirements for submission of product information to poisons centres in EU member states

INTRODUCTION

In the past eight years, the European Association of Poisons Centres and Clinical Toxicologists (EAPCCT) has been intensively involved in a European Commission led process to develop EU legislation on the information of hazardous products that companies have to notify to EU Poisons Centres (or equivalent "appointed bodies"). As a result of this process, the Commission adopted Regulation (EU) No 2017/542, amending the CLP Regulation by adding an Annex on harmonised product submission requirements. Harmonised mixture information requirements: Detailed and consistent information on the composition of the hazardous product will become available to EU Poisons Centres (PC). The information will be submitted by companies to PCs (or equivalent "appointed bodies") using a web-based software application or in-house software. Two new important features are introduced. Firstly, to be able to rapidly identify the product formula, a Unique Formula Identifier (UFI) on the product label links to the submitted information. Secondly, for better comparability of reports on poisonings between EU member states, a harmonised Product Categorisation System will specify the intended use of a product. Rapid product identification and availability of detailed composition information will lead to timely and adequate medical intervention. This may lead to considerable reduction in healthcare costs. Additionally, for companies trading across the EU, costs of submission of this information will be reduced significantly. Next steps: From 2017, an implementation period has started, consisting of a three-year period for stakeholders to implement the new requirements, followed by a gradual applicability for consumer products (2020), professional products (2021) and industrial use-only products (2024). Technical tools to generate the electronic format and the UFI together with guidance documents are expected to be made available by the end of 2017 by the European Chemicals Agency (ECHA). Guidance on interpretation of legal text and ECHA helpdesk support are planned to be ready at the end of 2018.

Evaluation of frameworks for ecotoxicological hazard classification of waste

A new harmonized EU regulation for the classification of waste came into effect on 1st June 2015, in which the criteria and assessment methods for the classification of hazardous waste are harmonized with other internationally agreed-upon systems for hazard classification of chemicals (CLP). However, criteria and guidance for the assessment of ecotoxicological hazard (Hazard Property 14, HP14) are still lacking for waste classification. This paper have evaluated and compared two HP14 classification frameworks: (i) a calculation method (summation) for mixtures, and (ii) leaching tests. The two frameworks were evaluated by surveying and evaluating ecotoxicological data for Cu, Zn, K and Ca species in bottom ash from incinerated waste, together with geochemical speciation modelling. Classification based on the summation method proved to be highly sensitive to the choice of speciation and ecotoxicological classification. This results in a wide range of critical concentrations triggering hazardous classification (in particular for Cu and Zn). Important parameters governing the availability of toxic elements, such as transformation from one species to another and complexation on organic or inorganic sorbents, are not accounted for. Geochemical modelling revealed that a testing strategy built on CLP based leaching tests (liquid/solid ratio (L/S)⩾10,000, pH range 5.5-8.5) avoids bias and is superior to the summation method with respect to both precision and accuracy. A testing strategy built on leaching tests, designed for risk assessment purposes, (L/S ratio of 10, natural pH of the ash) severely underestimate the hazard associated with the presence of toxic compounds (Cu and Zn), while simultaneously falsely indicate a hazardousness due to the presence of non-toxic compounds (Ca and K). However, the testing methods adopted by CLP are problematic from a practical and functional point of view. To conclude, the L/S ratio and pH were found to be critical for hazard classification based on leaching test methods. Further studies are needed to develop a relevant, practical and functional testing strategy for HP14 hazardous waste classification.