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ECHA Announces RAC Concludes on Opinion for Harmonized Classification and Labeling for Titanium Dioxide

The European Chemicals Agency (ECHA) announced on September 27, 2017, that the Committee for Risk Assessment (RAC) concluded on ten opinions for harmonized classification and labeling (CLH), including titanium dioxide.  In May 2016, France submitted a CLH proposal for titanium dioxide, stating that titanium dioxide should be considered as being potentially carcinogenic to humans when inhaled and thus be classified as category 1B-H350i.  France proposed that the classification apply to both fine particles and nanomaterials of titanium dioxide “without being able of any distinction in terms of morphology, crystal phase, and surface treatment.”  As reported in our June 12, 2017, blog item, during RAC-41, held May 29-June 2 and June 8-9, 2017, RAC “concluded that the available scientific evidence meets the criteria in the [Classification, Labeling and Packaging (CLP)] Regulation to classify titanium dioxide as a substance suspected of causing cancer through the inhalation route.”  The annex to ECHA’s press release states that RAC adopted the final opinion in written procedure before RAC-42, held September 18-22, 2017.  RAC did not agree to the proposal to classify titanium dioxide as category 1B, presumed to have carcinogenic potential for humans, but “agreed to classify titanium dioxide in category 2 as a suspected human carcinogen Carc. 2; H350 (inhalation), i.e. not by the oral or dermal routes.”  ECHA states that the opinion will be available on RAC’s web page “in the near future.”

©2020 Bergeson & Campbell, P.C.National Law Review, Volume VII, Number 271
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Lynn Bergeson, Campbell PC, Toxic Substances Control Act Attorney, federal insecticide lawyer, industrial biotechnology legal counsel, Food Drug Administration law
Managing Partner

Lynn L. Bergeson has earned an international reputation for her deep and expansive understanding of the Toxic Substances Control Act (TSCA), the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), European Union Registration, Evaluation, Authorization and Restriction of Chemicals (REACH), and especially how these regulatory programs pertain to nanotechnology, industrial biotechnology, synthetic biology, and other emerging transformative technologies. Her knowledge of and involvement in the policy process allows her to develop client-focused strategies whether...

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Carla Hutton, Bergeson Campbell PC, global regulatory attorney, public health activists lawyer, metals industry legal counsel, Toxic Substances Control Act law
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Since 1996, Carla Hutton has monitored, researched, and written about regulatory and legislative issues that may potentially affect Bergeson & Campbell, P.C. (B&C®) clients. She is responsible for creating a number of monthly and quarterly regulatory updates for B&C's clients, as well as other documents, such as chemical-specific global assessments of regulatory developments and trends. She authors memoranda for B&C clients on regulatory and legislative developments, providing information that is focused, timely and applicable to client initiatives. These tasks have proven invaluable to many clients, keeping them aware and abreast of developing issues so that they can respond in kind and prepare for the future of their business.

Ms. Hutton brings a wealth of experience and judgment to her work in federal, state, and international chemical regulatory and legislative issues, including green chemistry, nanotechnology, the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), the Toxic Substances Control Act (TSCA), Proposition 65, and the Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) program.

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