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DetNet Detergent Industry Network for CLP Classification
(skin and eye effects)
An A.I.S.E. Initiative
A.I.S.E.’s project for CLP
implementation
Adequate safety assessment for skin and eye effects,
based on in vitro test data
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Toxicological /classification
and safety data
Share expertise to use and
interpret data
New method and data
generation
(in vitro)
Classification process
Industry network (WoE/
expert judgement)
Stakeholder dialogue
Detergent Industry Network for CLP Classification
An A.I.S.E. initiative
Legal background
CLP Regulation, Annex I (paragraph 1.1.0.):
Suppliers may cooperate through formation of a network to share data and expertise
Suppliers should document fully the basis on which classification decisions are made
Suppliers should make data and information on which classifications are based available to authorities on request
Each supplier remains fully responsible for the classification, labelling and packaging of products placed on the market
3 Detergent Industry Network for CLP Classification
An A.I.S.E. initiative
DetNet
Scope
Products:
Laundry detergents (liquids & powders)
Hand dish wash detergents
All-purpose cleaners (non-extreme pH products)
Alkaline bleaches
Other cleaning and maintenance product types with similar chemistry (e.g.
car wash products)
Consumer and professional products
Note: other products may be added in the future (e.g. concentrated liquid
laundry detergents, extreme-pH products)
Endpoints: skin and eye irritation/ corrosion
4 Detergent Industry Network for CLP Classification
An A.I.S.E. initiative
DetNet
Unique features
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Web-based IT system
IT-system searches the database
of Reference Tested Mixtures
Security (individual access code),
confidentiality protected
Standardised process and records
Classification Record using a standard
format
Classification logging number as proof
Classification explanatory notes
Data sharing for all users, expertise
More than 200 mixtures, including recent market
representative products
Enhanced composition details on Reference
Tested Mixtures
Recent in vitro data using enhanced test method
for eye effects
Data quality and robustness assessed (Klimisch
scoring)
Study Summaries available
Scientific Advisory Panel comprising experts from
academia
Training and support
Training of classification experts
Help Desk support
FAQ
Detergent Industry Network for CLP Classification
An A.I.S.E. initiative
DetNet: Organisational structure
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DATABASE
- ca 200 formulations
- toxicity data:
historical in vivo
new in vitro Network Management
- Process
- Database
SCIENTIFIC ADVISORY
PANEL
“Guidance &
Quality Assurance”
- Medical/Toxicological
experts from e.g. Academia,
Poison Centers…
Secured Web / IT tool
EXPERT POOL
- Internal and External
experts
- Nominated/Trained
Evaluation/
Classification
COMPANY
placing product on
the market:
Responsibility for
final classification
AUTHORITIES Access info on
request
Detergent Industry Network for CLP Classification
An A.I.S.E. initiative
Experts
Options for company
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COMPANY
Nominate classification expert
In-house Employee Company-retained
consultant
Contract external experts
Eligibility criteria + mandatory training
“Expert pool”
Detergent Industry Network for CLP Classification
An A.I.S.E. initiative
Classification experts:
Eligibility criteria Classification experts should fulfill at least one of the
following criteria:
• Bachelor degree (in chemistry or biology) and at least 5 years
industry/regulatory safety/toxicology experience;
• Relevant Master’s degree and at least 3 years of experience;
• Relevant PhD and at least 2 years of experience;
• Candidates holding a further relevant professional qualification (e.g.
European Registered Toxicologist (ERT), Diplomate of the American
Board of Toxicology (DABT)) or being members of internationally
recognised groups of experts may not have to meet the above
criteria;
• Other candidates with qualifications not listed above will be
considered by the SAP on a case by case basis.
8 Detergent Industry Network for CLP Classification
An A.I.S.E. initiative
A.I.S.E. Classification Guidance
for DetNet classification experts
9 Detergent Industry Network for CLP Classification
An A.I.S.E. initiative
1. Identification of available
information on the mixture
and ingredients
2. Check pH (extreme pH
or not)
3. Compare with previously tested
mixtures (hazardous): can
“permitted variations”
Bridging Principle (BP) be
applied?
4. Can “dilution” or
“batching” BP be applied?
5. Are there 2 TM of same
classification that could be
used for “Interpolation”
BP?
Check Tested Mixture in DetNet
database, select possible Tested
Mixtures (TM) and apply BP
6. Is there a TM of same
classification that could be
used for “Substantially
Similar Mixture” (SSM) BP?
7. Is/ are there TM(s) that can
be used for “Interpolation”
or “SSM” BP using expert
judgement?
8. Is/ are there TM(s) and/ or available
information allowing WoE
assessment using expert
judgement?
9. Generate new data (e.g. In vitro) or
apply Additivity Approach
Yes :
Classify
Yes :
Classify
Yes :
Classify
Yes :
Classify
Yes :
Classify
Options in case no suitable Tested
Mixture is found
A member company that has not found a suitable Tested Mixture in the
DetNet database has the following options:
Conduct an in vitro test at company level (check suitable methods)-
could be shared with A.I.S.E. for inclusion into DetNet datase;
Derive the classification using the calculation method.
10 Detergent Industry Network for CLP Classification
An A.I.S.E. initiative
Classification Record (p.1)
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CLP Annex I
1,1,0: Suppliers
should document
fully the
classification
basis; data and
information to be
made available to
authorities on
request
Detergent Industry Network for CLP Classification
An A.I.S.E. initiative
Access by authorities
• DetNet users can share with local enforcement
authorities the DetNet Classification Record and
the study summaries if needed;
• After reviewing this available information,
authorities may contact the A.I.S.E. DetNet
manager to request detailed information on the
Tested Mixtures used (i.e. full compositional
details, full study reports…)
12 Detergent Industry Network for CLP Classification
An A.I.S.E. initiative
CONCLUSIONS
More than 200 experts from 150 companies have been trained to
correctly access and use DetNet
More than 1,000 detergent mixtures classified using data from DetNet early 2016
DetNet is the first Industry Classification Network for mixtures - Building on CLP: hierarchy of data, bridging principles, expert judgement, classification network.
- Use of in vitro methods to generate new skin and eye data.
- Data-sharing at A.I.S.E. level for a sector-consistent approach.
- Transparency and documentation.
A.I.S.E. has more work ahead: more data into the database, more dialogue with authorities, work on science…
We welcome your feedback
13 Detergent Industry Network for CLP Classification
An A.I.S.E. initiative