Page 38 - 2018 October Bar Journal

the basis for many legislative provisions on this information in their C&L notifications
the risk management of chemicals. or registration dossiers. ECHA maintains
Protest Art Additionally, the classification and labelling the C&L Inventory, but it does not review

of certain hazardous chemicals is harmonised or verify the accuracy of the information.
In summary, the above smattering of
Free Speech and Its among member states to ensure adequate risk chemical regulations demonstrates how alert
management throughout the EU. Member states
Legal Boundaries and manufacturers, importers or downstream companies must be when selling, importing
users may propose a harmonised classification or exporting products with chemicals in the
and labelling (CLH) of a substance. Only member United States or in Europe. By the way, China
states can propose a revision of an existing and other Eastern countries have chemical
CLE & public presentation harmonisation and submit CLH proposals when regulations with their own nuances. Be careful
by the CMBA's a substance is an active substance in biocidal or when trying to navigate such varied rules and
plant protection products. regulations, and please seek able legal counsel
The notification obligation under CLP to ensure compliance.
requires manufacturers and importers
to submit classification and labelling
information for the substances they John A. Heer has over 26 years of
are placing on the market to the C&L experience practicing environmental
Inventory held by the European Chemicals law, including experience with
Agency (ECHA). The Classification and traditional environmental issues
Labelling Inventory or “C&L Inventory” relating to the Clean Water Act,
is a database maintained by ECHA Resource Conservation and Recovery Act, the
Save the date! containing classification and labelling Clean Air Act, the Toxic Substances Control Act,
Federal Insecticide, Fungicide, the Rodenticide
information on notified and registered
Nov. 29 substances received from manufacturers Act, Comprehensive Environmental Response,
Compensation, and Liability Act, Brownfields,
and importers. It also includes the list of
at SPACES Gallery harmonised classifications and the names wetlands and stormwater. He has been a CMBA
of harmonised substances translated in all member since 1991. He can be reached at (216)
EU languages. Companies have provided 348-5400 or jheer@mcdonaldhopkins.com.

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38 | Cleveland Metropolitan Bar Journal clemetrobar.org