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Regulatory
Posted By:
Trace One
Prosisoft HSM, the hazardous substance management solution integrated in Microsoft Dynamics, has to change constantly. On the one hand, our product should support all common NAV/BC versions; on the other hand, new legal requirements require adjustments and additions. But we at Trace One GmbH also see ourselves as “innovation drivers”.
Below you find a brief description of what we have in the pipeline for early 2022. Ideally, we can install the update of the HSM version, the new dangerous goods classification and new SDS requirements "in one go". We can also deliver the SDS according to Regulation 2020/878 from the end of October 2021.
New HSM version
We have bundled previous changes and extensions to the HSM core functionality in HF version updates. The "HF" stands for "Hot Fix", i. e. for a smaller update, not to be confused with smaller adjustments for the acute needs of individual customers, which we have delivered as a preliminary version and included in the collection for the next general update. This time, so many improvements and enhancements have accumulated that we will bring out a so-called major release to version 2.0.0.0.
Dangerous goods classification in the FCC
The dangerous goods classification of mixtures has so far not been done in the FCC (Flow Chart Calculator) like all other calculations (GHS classification, WGK etc.) but via the PSSDOM, an external database and external program libraries (DLLs) outside of Microsoft Dynamics. With the inclusion of this functionality in the FCC and the elimination of the PSSDOM, the maintenance of your HSM installation will be considerably simplified (no more PSSDOM setup for each new computer!).
The new FCC configurations map the dangerous goods regulations much more deeply and consistently. Company-specific specifications (defaults) can be specified much more precisely. We will offer you webinars to inform you about this. We plan the roll-out beginning first quarter of 2022.
Diisocyanates
The EU regulation 2020/1149 added entry 74 (Diisocyanates) to Annex XVII of the REACH regulation. According to this, members of this group of substances may in future only be used in mixtures (individually or in combination) if their total content is below 0.1%, unless the users have been trained in safe handling (reference date: 24.08.2023). From 24.02.2022 the supplier must ensure that the customer is informed accordingly. On the label, there must be the following statement, clearly separated from other information: “As from 24 August 2023 adequate training is required before industrial or professional use”.
Trace One offers you an implementation package with the calculation of the total diisocyanate concentration and the output of corresponding phrases in SDS sections 2.2, 15 and 16 (training advice).
RCP calculation for workplace exposure limits according to TRGS 900
The German TRGS 900 divides the relevant hydrocarbon mixtures into three fractions or RCP groups with different workplace exposure limits (AGW = Arbeitsplatzgrenzwerte): C6-C8 aliphates (700 mg/m³), C9-C14 aliphates (300 mg/m³) and C9-C14 aromatics (50 mg/m³). These AGWs must be specified in the Safety Data Sheet of corresponding product formulations, provided that their hydrocarbon content falls into exactly one of the categories mentioned. If the product contains components of several categories, the AGW shall be calculated according to their proportions according to the RCP formula (RCP = Reciprocal Calculation Procedure).
Trace One can offer you an RCP calculation package for the FCC.