Send Varied Required with airSlate SignNow

Send varied required

hello and welcome to this webinar on what you need to know when notifying hazardous mixtures to appointed bodies so that the information can be made available to poison centers for the purposes of an emergency health response my name is Heidi rasa khari and today I will be your moderator due to the exceedingly large number of registrants for this webinar we will be rerunning what you see here today on the 10th of October this webinar is relevant to industry who may have obligations to notify hazardous mixtures as a result of annex 8 of the CLP regulation as well as the appointed bodies and poison centers who will receive and use the information contained therein in today's webinar we will explain the current status of the eco related poison center project you will also hear about the outcome of the feasibility study for the poison center notification portal and you will also hear from industry some ideas on how to start getting prepared for the deadlines you can submit your questions related to the presentations seen here today at any time during the webinar through the Q&A panel visible in your webinar window if you are experiencing any technical problems then please use this panel to let us know and we will help you fix the issue our panelists are on standby to answer your questions through the Q&A panel and we will endeavor to answer as many as possible however if you do not receive an answer before the end of the webinar you can always resubmit your question to your national helpdesk or to the echo helpdesk the echo helpdesk can be contacted using the address on your screen this webinar will be also published on our youtube channel as well as on the echo website so let's first start with a status update on the echo poison center presented by Mercedes Venus Thank You Heidi and hello everyone my name is Matthias Venus and I'm having the dosia submission and pick unit here in eka in the next ten minutes I'm going to give you an overview of where we are with the poison centers project and all the different aspects included in this project this project started when the new onyx to the CLP regulation was published earlier this year in March 2017 the new onyx gave new obligations for importers and downstream users that place has of those mixtures on the EU market giving them an obligation to notify information on emergency health response to the National appointed bodies this needs to be done following different deadlines depending on the end use of the hazardous mixture if the hazardous mixture is for consumer use the information needs to be submitted to the appointed bodies by 2020 if it's for professional use or industrial use the different deadlines are 2021 and 2024 and there is a transition period ending in 2025 for mixtures that were already in the market before this obligation started the nx8 gave new obligations foreca to give support technical and scientific guidance and tools to facilitate the submission of information these tools and guidance and support include a format for the notification that needs to be submitted to the appointed bodies a product categorization system that provides the different categories that need to be used to classify the product that are on the market in a harmonized way the unique formula identifier generator that generates a unique identifier for its mixture placed on the market and then the potential development of a central notification portal this became apparent when it realized that there was a harmonized format for notification of mixtures across Europe then the question came up why don't we build a central notification portal so that companies can notify centrally and their members they don't need to develop a notification portal in the different Member States now we will hear more about this later finally it gave eka the mandate to provide guidance and support material for all the different actors new obligations under this annex so where are our timelines this year we are working to finalize the tools meaning the format the generator and the product categorization system we aim to have them available early next year we're also starting with the preparation of all the support material that needs to be made available later on and we're also conducting a feasibility study on this central notification portal to conclude whether it's feasible and also to see how it may look like and what it means for ekak next year we will start the development of this central portal according to what is decided following this feasibility study we will also continue working on the guidance and support material so that is completed on time for the first notification deadline the aim is therefore that in 2019 we will have all the formats the tools the guidance and all the support material in place under central portal ready at least in its first version we also have a poison centers website life you can access it through the eka website and also you have the direct link on your slides we are also going to have soon the outcome of the feasibility study on the central notification portal available on this website and we're also having three different working groups where we are working with our stakeholders to produce all this material we'll have a guidance working group we have a working group that looks after the product categorization system and we also have a working group that is taking care of all the different IT tools but let's look at all of these different aspects in a bit more detail we start with the guidance and support we are developing a guidance document in two phase we are currently under the phase 1 which is taking care of a drafting there is a very active involvement of authorities on industry we are the working group and we are planning a workshop in early December to put together all the various inputs that we have received so that we can have a first draft ready by the end of the year we will then go to a phase 2 where we will start a formal consultation with all the different partners with all the different stakeholders we will launch this consultation in you one of next year so the final guidance can be ready by the end of 2018 but there is more support we are having questions and answers published on the poison Santa's website and they are regularly updated so we invite you to visit this webpage for new updates we're also working on targeted support for companies this is under development and we're planning to make it available as soon as possible you will hear more of this later we are also planning to train the national helpdesk so that you can ask them all the different questions in your own language and you have readily available help finally we are planning to make a FAQ sheet available on the unique formula identifier so that you can have answers to all the different questions that may arise when you try to generate these unique identifiers for your products now let's look at the product categorization system the PCs this system provides product categories for the different products in the market the idea is that this information is included in the notifications so that companies can assign up the relevant product category to their products when they notify it is a single selection based on the main intended use of this mixture the idea of this system that is also supporting appointed bodies at EU level on the report in a statistical analysis obligation it can also be used by poison centers for backtracking for example identifying how many incidents that they received are related to a specific type of product in your slide you can see a very simple supply chain to illustrate what we mean with this product categorization system you can see the first formulator that places on the market a mixture a pigment for example as this mixture is subsequently added into another formulation that ends up in different products one of them is consumer this first mixture needs to be notified by 2020 related to the consumer use deadlines the product category that must be selected in this case is a pigment this mixture is then reformulated in to the final products by the second formulator the second formulator needs to notify these final products that got into the market as you can see we are looking at three different products for consumer professional and industrial use they therefore have different deadlines as we saw at the beginning in 2020 2021 and 2024 they also need to be notified according to their corresponding product categories hobby paints for consumer use decorative coatings for preparation professional user and automotive coatings for industrial user this product categorization system is published in a draft form since earlier than a next year on our website we are aiming to have a final version of it by December this year we have very active participation for all different industrial sectors as well as appointed bodies and poison centers we are the working group and we're also planning to develop a practical manual that can help companies select the appropriate product category system product category for their products as this system will be evolving over time we're also trying to put together a process that will keep it updated and maintained over time now let's move to the generation of unique formula identifiers these identifiers are a set of 16 characters that will be placed on the label of the hazardous mixtures are on the market the idea is that you can uniquely identify unlink a product that is on the market to a notification that has been sent to our appointed bodies the purpose of having this code is to allow poison centers to quickly retrieve the information from the corresponding notification by eye including this UV code in their system we have a generator that is a system that allows you to generate already this unique identifiers for your products but we also have an algorithm with a guide for developers that you can use discuss with your IT providers so that you can integrate in your system and generate yourself this unique formula identifiers for your products we also have a notification format coming up there is a draft format already available but it is dated from 2015 and is currently obsolete we are aiming to have a final version by q1 next year due to the revised information requirements following the publication of this on x8 but it will also be aligned with standards format that are already induced on chemicals management like the Euclid XML format we will have this final version ready earlier next year and we hope is used and prepared by companies on their portfolios finally we are looking into this possibility to develop a central notification portal in eka as I mentioned before this question came up when realizing that we were having a harmonized format for notifications across the EU then it came up the point of why don't we submit centrally having economies of scale at EU so that we don't need to develop multiple notification portals in the different member states but instead we will submit one signal point centrally in EU we also aim to ensure a high level of security having a secure Isis access in a single point instead of multiple entry points across Europe we aim to increase the efficiency for industry for this process as well as facilitate an exchange of information among member states in a way that we will leverage the benefit of having harmonized format for these notifications across Europe we will hear more about this central notification portal from our colleague Amandine in the next presentation thank you very much for your attention [Music] Thank You Massa Dez hello everybody my name is Amanda engineer and I am working in the poison centers team Atika in the following slides I will present to you the outcome of the feasibility study on what are the next steps before that I would like to first present or remind what were the main objectives of this study identifying the value stakeholders and analyzing the needs proposing a solution for the central portal producing a blueprint of a candidate architecture for the system that will fit into a kawaii architecture defining the best approach to the delivery and providing early estimates of development costs and efforts so the first objective of the feasibility study was to analyze the needs of the value stakeholders in the context of a poison center notification portal the main actors were identified as industry users appointed bodies poison centers and ayka additional stakeholders such as the Commission the Member States competent authorities and the enforcement authorities were also identified as potential actors however the relevant requirements have not been analyzed in this study and we will consider them in the future in a few words the portal will serve to support industry with preparing updating and submitting the notifications and dispatch them to the relevant appointed bodies the portal will ensure security and confidentiality of the data and support the needs of all actors regarding multilingualism the portal will also provide an automated submission process that will ensure that the submitted files are various free and conformed to this format specifications in addition the portal could support a set of checks or validations to ensure that key elements are included in the notifications for example the inclusion of a trade name in the file however these validations will first need to be discussed and agreed with the different stakeholders before they become integrated into the submission process we force these three levels of validations as part of the notification process before the actual submission industry will have access to tools that will inform them about the correctness of the notifications they are about to submit this will be supported directly within the submission wizard for example the mandatory field left empty would be alighted the validation tool can also be offered as well as an extra feature once the files are submitted they are validated within the PCN portal according to a man eyes technical on business-related checks once the file pi passes those harmonized validations they are dispatched to the appointed bodies appointed bodies have done the possibility to further check the quality of the received information those quality checks are performed at national levels what will be the best approach to develop this portal the proposal is phased out is a phased rollout that will reduce the risk and offer the possibility to test changes before it moves to full implementation in that way it can support ongoing modification and improvement stakeholders can test the system and provide opinions improvements as the project evolves this staggered approached for the delivery would consist in developing and first Minimum Viable Product MVP in 2018 that will be followed with a major release in q3 2019 therefore all features that have been identified as core would be developed before the first deadline while the release is providing additional features are foreseen in the following years these tables present a summary presents a summary of the core functionalities that are foreseen to be supported by the portal before the end of 2019 the MVP will provide a multilingual and secure web tool for industry to applaud and submit their notifications the MVP will also offer a secure portal for appointed bodies on poison centers to receive and download the notifications an automated submission process will ensure that submitted files conform to the format specifications the MVP will also offer a searchable repository containing the full history of the notified data and will support basic basic user and contact management functions in its second version the version to the portal will support the online preparation of the notifications using a dedicated web user interface web services integration layers will be exposed to both industrial Member States IT systems the automated submission process could also support more automated business checks in the following slides I will present one by one the main features of the portal character and indicate for which release they are foreseen I would like to highlight the dis list of functionalities and the current prioritization are a proposal based on feedback received by the different stakeholders we can review the list as well as the priorities in general the priorities have been decided based on the time constraints the requirements expressed by the different stakeholders the logical order of events and the readiness preparation expected from the other actors let's start now with the features that will be available for all users please note that the mock-ups that you will see on the slides are for illustration and purposes only on the port I may look different when it is released the MVP will support the symbol is a simple signer procedure through integration with the accounts for user registration an authentication service as well as words administration in the MVP each sector will have access to a home page with a set of functionalities and the menu will be tailor-made according to the user role the interface will of course also be available in all EU languages and such functionalities will be operational in the second version support in all EU languages will be extended to online help this help could be contextual as shown in the mock-up or provided field by field to the user in the MVP all users will have the possibility to access their share of the data search for the notifications view trained under load them the user may decide to download one or several notifications at a time the portal will offer message box to all actors where users can manage messages received by the portal in a future release the portal could support the secure exchange of messages between actors and the possibility to the possibility to create a task in addition to a message a task could be for instance indicating a need for action by a certain deadline the MVP will provide a comprehensive audit functionality were selected key business events and actions are locked together with the user initiating the action in the next slide I will present the foreseen feature specific for industry users in order to support the preparation validation updates submission and management of the notifications the MVP will offer a web interface for industry to applaud and submit the notification files that they are I've been preparing offline those files could be initial notifications or updates of existing notifications industry users will also have the possibility to upload and submit multiple files at a time the MVP will support the possibility to include several member states in one notification and submit it to the relevant Member States the notification can be prepared in the industry user users preferred language and will be made available to the appointed bodies and poison centers in their own preferred language only free text field would need to be provided by the user in all relevant languages another core feature that will be developed for the second version of the portal is the online wizard offering the possibility to fill-in and submit a notification online users will have the possibility to save a draft on their local file system on reopening later on the advanced version of the portal could support the saving and opening of an online draft without having to save it on any local system the second version of the portal will make a tool available to validate a notification file in the portal offering the possibility to industry to check the files before the actual submission while the MVP will offer the possibility to submit an update notification without a web user interface the version 2 will offer the possibility for industry to perform those tasks with our web services an advanced version of the portal could also support the retrieval of notifications for system to systems integrations as part of the MVP users will have the possibility to manage their contacts that need to be included in the notification the contacts can be created updated and assigned to specific notifications in the version 2 tracking dependency between contact records and notifications would be supported to avoid resubmission in some specific cases version 2 of the system will also integrate with the egg has substance inventory to provide a level of automation an assistant when the user provides a mixture components identifiers such as EC or caste numbers can be used to retrieve the substance entry business checks could also validate the correctness of the identifiers provided by the user finally the portal will also serve to provide support with legal entity changes we have indicated this feature as advanced for the moment only because it needs further analyzes but it might be decided to try Ora ties it already for version 2 let's now have a look at the features specifically foreseen for the appointing bodies on the poison centers the portal will provide access to the notifications that are relevant to their territory and also to specific national processes while the MVP will provide access to the notifications through a web user interface and allow appointed body and poison center users to search view on download notifications the second version will be enhanced by offering the possibility to receive the notifications via web services directly into their local systems all the quality checks remained at national level however the portal could support the related process our communication channels it could allow appointed bodies to record that a specific notification has been checked and positively informed the industry user of the outcome of the notification or send a request for clarification in the scope of a reason request an advance version of the portal could also provide the possibility to annotate problematic fields in the notification invoicing also remains that national level however here again the portal could provide some support and indicate to industry possible fees per Member States or provide reports to Member States to support the National invoicing process the portals objective is to support the notification process by providing a secure integrated platform where industry actors submits notifications while member state actors search access and retrieve them in earlier discussions a number of EU Member States expressed their interest on fully relying on a key hosted IT services to replace the need for local IT systems for their appointed bodies or local tourism centers this requires a CAD to offer dedicated IT services to Windows to interest in Member States following bilateral agreement an extended scope of the centralised bottle until now only ideas have been captured but these services would offer a dedicated environment we need with increased availability and could provide other advanced analyses such as support for advanced search and reporting capabilities support for recording incident data or a workflow to support the quality check at national level however these functionalities need to be further defined and prioritized according to the needs of the interested member states to conclude on the foreseen functionalities the slide summarizes all the earlier mentioned features and provide an overview of what the first three version of the portal would support but what about the architecture as mentioned earlier another main deliverable of the study was to provide to produce a blueprint of a candidate architecture for the new system that fits into ekiz IT architecture the main principles that have been followed were the following reusing as much as possible existing solutions whose effectiveness have already been demonstrated favoring standard solution instead of custom ones and separating concerns between components to allow incremental evolution of the solution all these needs to fit with the eka ite architecture and be delivered within the agreed timelines the main conclusions led to use the following existing solutions having standardized formats and therefore making the PCM format compatible with euclid xml reusing the accounts for registering authenticating and administrating users and parties integrating with eka substance repositories to support the preparation and validation of the notifications reusing our reporting platform to support the compilation of reports on relying another existing infrastructure elements to support security viral scan or email services in this slide you can see a high-level representation of the proposed architecture including the different components that were mentioned it also shows the integration points with industry and member state national systems for industry appointed bodies on poison centers this slide would be of interest for your IT providers further technical documentation will also be made available building a central notification portal will also imply supporting all services that will be related to the development on the functioning of the system training material will be made available on unsigned trainings will also be organized by a cow a cow will also organize communication on awareness raising campaigns helpdesk support will be provided to industry in cooperation with the Member States Annika will also closely work with the member states to support them with the implementation we encourage all stakeholders to express their needs to us to conclude I would like to first present the high-level timelines and then discuss the next steps as you can see in this timeline we are currently located somewhere in the last quarter of 2017 and elegant text was adopted around seven months ago the final vision format is planned to be published in the first quarter of two thousand eighteen while the MVP of the portal will be released in the quarter for of 2018 the second release of the portal including the core functionalities is planned for q3 2019 and the following release is planned for through 2020 the work to prepare for the two first releases will have to start as soon as possible to make sure both will be ready according to those timelines the immediate next steps include the following to continue on refine the analysis of the needs of the various stakeholders to finalize the notification format to develop and agree on varied rules to continue the analysis of the architecture on the security model a current security model might need to be adapted to fulfill the needs of industry on member states in the context of the poison centers project the next decisions that would be essential for this project at the next meeting of the member state competent authorities in October the next caracal meeting in November and the ik a management board decision of December we encourage you all to continue with the preparation for being ready member states you have to decide on inform on the options you want in order to receive and manage the notifications will you accept notifications from the PC and portal will you need dedicated hosting services in addition to what is offered by the central portal and for all actors we encourage you to support the business analyzes and express your needs to make sure we develop what you need and we hope you all start to build capacity to support next year's development phase and get involved in the testing I would like to thank you very much for your attention and before I hand the floor to Blanca you can find on this last slide the email address of the poison centers team on the address of the poison centers website hello everybody I am blanca serrano the CLP manager manager in suffolk chemical the european chemical industry council and i'm here to give you a presentation for industry by industry on how to you can prepare for the notification to the poison centers according to annex 8 of CLP so first of all you need to know your obligations and your obligation is to notify who needs to notify all those importers and downstream users that place mixtures on the market are responsible to notify to the poison centers what do they need to notify they need to notify those mixtures that are classified as hazardous for human health or physical hazards that means that no mixture is classified for environmental hazards need to be notified or also gases under pressure or explosives and why is this that's because the objective was this notification is to provide appropriate emergency response in the case of intoxications for example and those mixtures that are only classified for environmental hazard are not going to be need that kind of emergency response and also physical hazards like gas and the pressure or explosive do need a different emergency response than the one that the paulson centers can provide when it is necessary to notify well the deadlines depends on the use of your mixture so those mixtures that are intended for consumer use need to be notified from generator from the first of January 2020 those mixtures that are for professional use need to be notified from the first of Yemen after January 2021 and the mixtures for industrial use need to be notified from the first of January 2024 the notification has to be done before the mixture is placed on the market so not placing it on the market and then do not the notification but do it in advance also there is a transitional period for those mixture that has been already notified through the national systems in the in the Polson centers and those mixtures can be notified from the first of January 2025 in the new system unless during that period there is a change in the mixture that requires an update in that case units already to use the new system and identify your deadlines according to the use to notify you need to use a harmonized poison center notification format that it's provided by eka in the webpage that is dedicated for the poison centers and later on in this presentation you will find the link to it and where do you notify this is something that is still being discussed and under development but the notification or the options we are hoping for is to be able to notify directly to the appointed bodies of the member states where the mixtures is placed in the market or through the acre poison center notification portal that is now being developed you need to up or to to submit different kinds of information first of all you need to submit general information like a product identifier that could be the trade name of your product identifiers of the mixture components caste number is in amber nuclear name or they could be different options sometimes it's not possible to provide all of the identifiers x' but those that you can then you also need to provide a unique formula identifier this is a new identifier that is created via a tool that is also provided by acre in the in the poison centers webpage this tool uses the BLT from the company and I you numeric identifier for your mixture that it's an identifier a numeric identifier you would have in-house so it's your own classification system let's say and with this bi T and this numeric identifier you can generate a unique formula identifier via web tool if the company doesn't have a BA T it's possible to get let's say fake vit to generate this you fi and this is because at the end there there is not real correlation between the be 80 and the UF is yes the be 80 is the means to generate at UF I but there is no numeric correlation that you can identify be at the UF i which companies it's coming from unit also to provide the contact details of the two submitter as part of the general information then the second section let's say it's a hazard identification so you will need to provide the classification of the mixture and the label elements as well as some toxicological information this toxicological information can be section 11 of the safety data sheet or you can add additional information if want then you need to submit information on the components of the mixtures so the components of the mixture need to be all identified with their container concentration even those components that are not classified as hazardous have has to be notified the concentrations can be expressed as exact percentages or as ranges and the ranges vary depending on the classification of the component so those components that are more concerning have smaller Ranger ranges to then then other components and those components with the title concentration ranges are those classified as acute toxicity category one two and three specific target organ toxicity for single and repeated exposure category one or two skin corrosion category one 1a 1b or 1 C and serious eye damage category one finally you need to provide additional information this additional information regards for example the type and the size of the packaging that the mixture is put on the market in the color the physical state and the pH of the mixture also the product category according to the EU product categorization system that it's now being well let's say finalized by acre but was started by the Commission and this is a categorization system that allows you to place your mixture according to a concrete use in a category or several categories like for example and these shapes or contracts construction products paints etc etc then you need to identify the general use let's say consumer professional or industrial and that would be the information that you need to submit to for the poison center notification there are at this point still discussions ongoing and preparations being made by all the stakeholders involved and especially ayka however you can start already preparing - for the notification and how can you do that first of all you need to know your portfolio this will help you to identify which mixture will require it requires submission of information to comply with the obligations of an exit of CLP you need to once you have identified the mixture that requires submission you need to identify the uses if it's consumer professional or industrial use and then you can see which which mixture enter in which deadline and prioritize accordingly for industrial mixture there is a special regime and you can do a limited submission of information this means the information that it's required for industrial mixtures less than that for consumer and professional mixtures however to do that companies should also provide a telephone number that is available 24 hours 7 days in an email address for rapid access in case the appointed bodies of the poison center need additional information another of the of the perks let's say is you can use some generic identifiers these generic identifiers are only 3 perfumes fragrances and coloring agents this means that you can group all the components of your mixture that are acting as perfumes as a category as a generic identifier and you don't have to specify them unless the components are classified you can only use these and kinetic identifiers when the components are not classified for health hazard otherwise you need to specify the components also for perfumes and fragrances the concentration should not exist exceed 5% in total and for coloring agents the concentration should not exist to exceed exceed 25% in total if it also it's also possible to do a group submission and submit several products in one go given that all the mixtures in the group contain the same components and the reported concentration rates is the same for all mixtures and so is the classification the another of the topics is the mixture in mixtures and I would say this is one of the most complicated issues for the notification a mixture in mixture is what's called a mixture that is used as a component of another mixture the manufacturer of this second mixture that has one of the components if a mixture might not know the full composition of this mixture because the supplier for know-how reasons of confidentiality might not provide the full composition but the safety data sheet where you have identified the hazardous components but not the full composition what do you do in this case well there are different options the first one would be to contact the supplier and ask if they could provide you with a complete composition of the mixture but you might find a no for an answer because this is know-how information from your supplier and they might want to keep it confidential then you have another option that is to provide the information of those components that are known to you and give them the product identifier of the mixture so the trade name of the mixture that you're using to create another mixture the concentration that has in your final product and the ufi that your supplier should have add in the package of the mixture that has been sell to you with this information it should be enough for the appointed virus of the poison center to reteach the full composition from the notification of your provider and then there is a third option and is that there is no UFA available they might be different reasons for that to happen I will not enter into detail but in that case you should give the information on the known components of the mixture and the product identifier and concentration of the mixture in mixture the safety data sheets name email address telephone number of the supplier of this mixture in mixture so these are the three options that you have to notify a mixture in mixture to summarize a little bit how do you get prepare first of all time flights and the first deadline 2020 might seem far away but is not so start as soon as possible identify your mixtures affected by unexcited CLP identify the use to determine the deadlines consumer professional or industrial use check the composition of your mixture and assigned ranges or exact percentages if you please and remember that different ranges are assigned depending on the classification of the substances make sure that the data you have are up-to-date and do have a system to monitor and manage changes because they might trigger updates consider to set aside budget for the necessary IT tools and resources also human resources to fulfill their obligations and start assigning you files to your mixture also get familiar with the product categorization system the EU pcs that defines the mixtures according to the intended users it is mandatory to use and one product complete in several categories as we know that chemical products and mixtures sometimes are versatile and have different uses well now we go to the point on how do you submit your product information and unfortunately at this point things are still under discussion so I can give you more questions of what we are thinking about what a guy is thinking about the Commission and other stakeholders but it's working well in progress the creation of a portal to do the submit the submissions also under consideration is if this portal would just be that a portal where you enter the information and then it's further distributed or if a kibbutz with the compounding all the information it's also under question if all Member States will allow the submission directly to the national appointed parties some of them have confirmed that it is going to be possible some have not yet so these are things that are still under discussion and the under question and also here as I said at the beginning I included the link to the webpage from eka dedicated to Paul sunset test that I'm sure they will provide also more information about it and you need you have information about the the notification format and the editor the ufi generator and and some more guidance and information that you can consult important thing is to keep the information up-to-date so once you have submitted work has not finished when it's an update required when the mixture or the product identifier included the ufi change or when the mixture classification for health and physical hassle has changed or when they are new relevant toxicological information available or data that you need to use and then you have also the possibility of a change of composition in the mixture this change may trigger an update or a full new notification so you need to evaluate if the change is requiring only an update or a new notification finally or almost finally there are some challenges to industry well and also to to other stakeholders involved it is a very complex regulation as everything that is related to to chemical regulations it's not it's it's always complicated and it's a new obligation that it's add up will be already existing deadlines like the last registration in 2018 changes in nucleus that might trigger updates of the CS updating in rich that may change the obligations of the registrants also resources have to be dedicated to fulfill these new obligations and the training of the employees and support will be critical in the future some definitions still need some clarification or need to be some decisions need to be taken let's say sometimes it is difficult for for a manufacturer for of a mixture to know the full supply chain and all the uses along it for different reasons confidentiality for competition law or simple because simply because supply chains tend to be really complicated and it's very difficult to map the full supply chain timeless are very tight for everyone that's not only a challenge for industry it's also a challenge for for the commission akka and they and the appointed parties I think new IT tools and guidance will be ready shortly before they entering into force so there is little time to get acquainted with the system and there are still some workability issues under discussion on some sectors that petroleum like petroleum products and construction sectors that would be further discussed one of the important points for us is to preserve confidentiality both by Iike that it's warrantied and all the appointed parties and also there are some concerns regarding the fees in some Member States because it creates some competitivity issues however I have to say that everybody is working really hard to make things possible and end up with a with a workable system so every variable is trying to achieve harmonization throughout Europe and get all the all the Member States in there on the same patron system to provide the information for the emergency response we're trying to make a collection of data that is useful for everyone and provide all the stakeholders with the needed support and guidance Thank You Blanca for the informative presentation well that was the final presentation for today and we hope you've gained some insight into the current status of notifying hazardous mixtures for poison centers the webinar is still open for you to submit questions until 12:15 Helsinki time so please do make use of the Q&A panel thank you to all for joining us today until next time [Music]