esdscom / sdscom-xml

Schema definition and other documents of eSDScom (formerly SDScom and ESCom), the standard for electronic exchange of Safety Data Sheets in a structured, processible way across Europe and other regions. Please read the wiki for more info. All work is licensed under CC BY-ND 4.0 (https://creativecommons.org/licenses/by-nd/4.0/legalcode)
https://www.esdscom.eu
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Add optional EUH0xx in section 3? #229

Closed dirk-qualisys closed 4 years ago

dirk-qualisys commented 4 years ago

EUH0xx are labelling elements for hazards which were covered under the old EU directives DSD/DPD, but not part of the UN GHS standard. It seems that under the building block approach, there was no way to add new hazard classes, so adding labelling elements was the best option. Nevertheless, the assessment of such hazards for a mixture requires looking at ingredients and their assessment for the same hazard. In other words, the justification of a EUH0xx for amixture often lies in an ingredient. Thus, it would make sense to transmit EUH0xx in section 3 of the SDS.

As it is not correct to list these as classifications, I suggest to add an optional field for supplemental hazards which covers such labelling elements. IT systems can choose to ignore or populate this field, depending on their philosophy, but it would allow other systems to print an SDS from an XML file including such info.