Compliance and the CMR registration

Which lists Chemspark checks

• CMR substances: carcinogenic, mutagenic or toxic for reproduction, recognised from the H statements in the SDS, suspected substances included.
• SVHC List: the European Candidate List of substances of very high concern under REACH.
• REACH Authorization (Annex XIV) and REACH Restrictions (Annex XVII).
• ZZS List: the Dutch list of substances of very high concern kept by RIVM.
• SZW List: the Dutch list of carcinogenic, mutagenic and reprotoxic substances from the Ministry of Social Affairs and Employment, with the category per substance.
• Your organisation's Custom Lists, such as a sector agreement or an internal ban list.

Chemspark compares the components from section 3 of the SDS, by CAS or EC number, with these lists. If a number is missing from the SDS, the substance cannot be recognised. The check runs again whenever a product is added, replaced or edited. When a regulatory list is updated and a substance in the organisation's products is newly on it as a result, a notification follows.

Using the Compliance page

1. 1Open Compliance in the menu. At the top, each list shows the number of products with a match.
2. 2Pick a list on the left to see only those products. The lists are grouped: European lists, Netherlands and Custom Lists.
3. 3Search by product name, CAS number or component, and sort by product name, location or number of flags.
4. 4Read per product which component is on which list, with the location and department where the product is kept.
5. 5Open the product for the details, or decide on a next step, such as substitution or the CMR registration.

Custom lists

1. 1On Compliance, click 'Manage Custom Lists' and create a list with a name and an optional description.
2. 2Upload an Excel file (.xlsx or .xls) or a CSV file with a column of CAS numbers. Name, EC number and notes may be included. A template can be downloaded.
3. 3Chemspark then also checks the products against this list, next to the regulatory lists, and reports new matches.

Custom lists belong to the organisation and apply to every location. In Reports they can be added as a column.

When a product falls under the CMR registration

Anyone working with carcinogenic, mutagenic or reprotoxic substances must keep a registration under the Dutch Arbobesluit, covering among other things the quantity, the type of work and the number of employees. For some of these substances the Arbobesluit asks for a limited registration.

Chemspark decides per product whether it counts. It looks at the supplier's classification in the SDS and at components on the SZW List, following CLP and the Arbobesluit. On Compliance the product shows 'Falls under the CMR registration', 'Falls under the limited CMR registration', 'Suspected, no registration duty' or 'Does not fall under the CMR registration', with the reason. The CMR registration filter groups the products that count.

Filling in the registration

1. 1Open the product in Risk assessment. Under the screening is the CMR registration block; it only appears for products that count.
2. 2Choose roughly how much is used per year.
3. 3Enter how many employees work with it and in which role.
4. 4If the product falls under the full registration, also state why it cannot be replaced, and confirm that the names of the people who work with it are kept in your own records.
5. 5Click 'Save registration'.

Chemspark takes the type of work, the measures and the PPE from the screening and the recorded measures. While questions are open, the worklist shows 'CMR registration: … questions open'.

Chemspark stores no names or health data of employees, only the number and the role. The list of names the Arbobesluit requires is kept by the employer in their own records, for example by HR or the occupational physician.

The CMR register

The overview is in Reports, under Quick reports: CMR register. It lists every product with CMR H statements or with a substance from the SZW List, suspected ones included, with per product whether it counts, why, and the registration answers.

If a product is deleted, its registration is kept; the CMR register then shows the product as no longer in use, with the date. If a new SDS changes the classification, the block asks to save the registration again.