Strategic planning and implementation in Market Inspection and Surveillance

1
Strategic planning and implementation in Market
Inspection and Surveillance

• Magdalena Noganska
• Chief Sanitary Inspectorate
• Department of Environmental Hygiene
• The State Sanitary Inspection

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Planning of Market IS

• Current surveillance
• register of enterprises
• Annual plans- thematic inspections
• European inspection action under CLEEN

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Current surveillance

• Particular number of enterprises have planned to
  control
• - role in the market
• - size (number of employees, number of product
  place on the market)
• - NEW ACTORS
• - Labour Code (employer application)
• - Information on dangerous prepartion from
  B.ChSP

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Annual plans- thematic Inspections
Annual Planning guidance of Chief Sanitary
Inspector
Course of actions Thematic inspections Terms,
period of realization reporting
Annual Plan of VSI
X 16
Annual Plan of PSI additional activities
X ..
Number of controls Names of enterprises Date of
controls Terms, period of realization Additional
activities
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PLAN FOR 2004

• Preparations containing methanol
• Preparations with denatured alcohol
• Biocidal products
• Wood preservatives
• Tin-organic compounds
• Recognizing market of mineral wool as a chemical
  product

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Biocidal products

• In 2004 2471 producers, distributors and those
  using biocidal products were controlled.
• From the received data appears that 98 of
  producers were controlled.
• In connection with lapses identified by sanitary
  inspectors administrative decisions concerning
  biocidal products were issued. In the whole
  country 290 decisions were issued

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METHYL ALCOHOL

• no producer of methanol was controlled
• 9 entities producing preparation containing
  methanol with concentration by weight of at least
  3
• 27 entities placing methanol into the market
• 24 entities marketing preparations containing
  methanol with concentration by weight of at least
  3,
• 61 entities using methanol in professional
  activities and
• 30 entities using preparation containing methanol
  with concentration by weight of at least 3 in
  their professional activities were controlled .

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METHYL ALCOHOL

• 96 of the products were correctly classified and
  of all the controlled entities only 2 did not
  have SDS
• all the controlled SDS 81 were correctly filled
  up.

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Plan for 2005

• Pilot project in the frame of PHARE 2002
• Activities under project PHARE 2002
• Common inspections
• Study visit

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Pilot project

• The basic aims of the Pilot Exercise in relation
  to the improvement of implementation status of
  provisions concerning the control of chemical
  articles were
• the creation of the network of cooperation
  between the institutions involved in activities
  in the field of the control of chemical articles
  
• training concerning specific skills and
  analytical methods
• cooperation between inspectors, laboratories and
  enforcement authorities
• the identification of deficiencies and the
  preparation of recommendations concerning the
  ways of improvement of cooperation between
  inspections.

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Pilot project

• Inter-institutional network of chemical products
  control has been built with co-operation between
  inspectors of sanitary, trade, labour,
  environmental protection inspection and custom
  service as well
• Beside network between inspectors co-operation
  between laboratories has been established
• In case of detecting the content of aromatic
  amines it was a lack of toys dyed with strong
  colours as mazarine, black, red or dark brown.
  Testing of such a products was one of the aims of
  the project.
• There is special need for technical trainings for
  laboratory staff and also meetings with chief
  representatives before making decision concerning
  participation in the future projects.
• Laboratory staff also expect technical trainings
  and inter laboratory meeting not only within one
  inspection but also between staff from other
  laboratories

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Plan for 2006

• Detergent according to regulation on detergents
  648/2004/EC.
• CLEEN projects CLEEN EUVICHEM, E-COMMERCE i
  AZODYES
• Chemical agents at the work place
• Biocide product masonry preservatives PT10
• Cooperation with industry placing on the market
  drug precursors category 2 and 3

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Plan for 2007

• CLEEN projects Euroazos, Eurobiocides.
• TF project REACH

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EurAzos

• The main objectives of the EurAzos project was to
  assess the compliance of the textile and leather
  articles and colouring agents placed/used on the
  European market with the provisions regarding
  aromatic amines of the Restriction Directive
  76/769/EEC (the 19th amendment and the 12th ATP)
  in order to minimise the risk for human health
  arising from the release of these substances from
  the mentioned products.
• The following goals of this project were
  considered to be most important
• reduction of risk to consumer from products which
  have direct and prolonged contact with human skin
  and oral cavity
• ensure risk reduction measures to be taken by
  provided adequate monitoring
• exchange of information and experience between
  Member States concerning product inspection
• strengthening of cooperation between inspectors,
  laboratories and enforcement authorities
  including interlaboratory studies concerning
  specific skills in analytical methods.

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Choice of the product

• Textile articles ? underwear, pyjamas, shirts,
  bedding
• Leather articles ? shoes, gloves
• Toys ? for children lt 3 years old
• Agents for colouring textiles

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Choice of the companies

• Textiles large shops with clothes and branches
  in all EU
• Leather articles shoes and handbag shops
• Shops with toys
• Shops with cheap goods

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EurAzos results

• Positive results were reported in 9 cases (2,49
  ), out of the of 361 products verified during
  the project. The positive samples were reported
  by the Netherlands (6), Poland (1) and Greece
  (2).
• It is difficult to establish criteria for
  selecting the samples to be analysed
• The analysed samples showed good compliance of
  the companies, as only 2,5 of the samples were
  in violation.
• The results of the project might be affected by
  some laboratory difficulties often it is
  difficult to achieve the same results in the same
  sample because of their heterogeneity (with
  regard to materials and dyes used)

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EurAzos - conclusions and recomendation

• to elaborate enforcement strategies for articles
• to support the cooperation between the Member
  States e.g. cooperation between accredited
  laboratories, cooperation between inspectors
• to develop testing methods for articles with
  mixed fibers, natural and synthetic
• to speed-up the procedure for the publication of
  the RAPEX notifications
• To the EU Member States/EEA countires
• to continue the enforcement activities for
  checking the compliance of the products on the
  market with the provisions of the Annex XVII of
  REACH Regulation on azodyes
• to cross-check some of their samples between
  different accredited laboratories located in
  different Member States ring cross-checking
  and use identical samples for this purpose
• to follow the RAPEX notifications and take action
  immediately (often the products notified through
  RAPEX are not present in shops anymore when the
  inspectors arrive)
• to inspect also expensive articles or imported
  colouring agents
• to ask the industry to pay for analyses if they
  are not able to prove their compliance
• To the Industry
• to ask their providers for the information on the
  composition of the products they purchase,
  including the used dyes
• to introduce quality management in the companies
  also with regard to substances that they are using

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PLAN FOR 2008

• Review of articles with intentional release of
  chemical substances and preparation
• Inspection of SDS according to REACH provisions
• Inspection of building chemicals in cooperation
  with TI, LS, EI
• Inspection of biocide products in relation to
  CLEEN project Eurobiocide
• Nickiel project with cooperation of Trade
  Inspection

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Enforcement tools

• Internal procedures (annexes- check lists, we are
  going to up to date some of them)?
• Guidance documents
• Guidance for compiling SDS
• Guidance document for inspectors REACH/GHS
• Guidelines documents concerning enforcement plans
  for 2008 (working group)

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POLAND AS A MEMBER OF CLEEN
European Enforcement Network

• C Chemical
• L Legislation
• E European
• E Enforcement
• N Network

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CLEEN PROJECTS

• The SSI participated in the following projects
• ECLIPS (European Classification and Labelling
  Inspections of Preparations including Safety
  data sheets) (2004)
• EUVICHEM (EUropean Voluntary Information Exchange
  System on CHEMicals)
• E-commerce (2006)
• EurAzos (2006-2007)
• EuroBiocides (2008)
• EUNICK Nickiel Project (2007-2008)

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ECLIPS Project

• 2002 - 2004
• Scope CL of preparations and SDS
• 1999/45/EEC 2001/58/EC
• Focus Consumer products with the properties
  dangerous for the environment,
  sensitizing, CMR, R67
• Results 60 of labelling,
• 65 SDS incorrect

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Results of the E-commerce Project

• Trade of chemicals by the Internet

• Internet shopping labelling, SDS and bans and
  restriction
• (Dir. 1999/45/EEC, 2001/58/EC, Dir. 2000/31/EC)
• Internet based marketing is a new and evolving
  medium for chemicals
• Inspectorates need information how to deal with
  it
• Many chemicals are dangerous
• Anonymity and remoteness of the parties involved
  in
• Internet sales increases an inherent risk of
  misuse
• Monitoring up to now only in special fields (e.g.
  pornographics, weapons)
• Violations have been found

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Why this Project?

• Internet becomes more and more used as a platform
  for the trade with all kind of goods and shopping
  by Internet gets more and more popular.
• Easy-to-reach a customer
• Anonymous
• Feeling of impunity
• Products/companies cannot be inspected immediately

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Some numbers ...

• Number of inspections - 45
• Is the geographic address given on
• the website? - 100
• Is website restricted? - 7
• Is substance/preparation dangerous? - 91
• Information necessary available
• on the website? - 27!!!
• Information correct? - 51
• Is substance restricted in
• marketing/use or banned? - 42

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Category of the company placing chemicals on the
market
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Number of Inspections in individual Voivodships
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CONCLUSIONS

• Low quantity sale
• Lack of knowledge on legislation
• Problems with identification of all
  companies/persons selling chemicals via Internet
• Internet Developing area that should be taken
  under control

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PROBLEMS

• Lack of unequivocal legislation regarding to
  placing chemicals on the market via Internet
  
• Troubles with identifying sellers
• No knowledge on legislation by the companies
  selling goods via Internet
• Lack of unequivocal definition of buying via
  Internet regarding to chemical products

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Source of proposal for planning

• New legislation
• New products
• Bans and restrictions
• Bans of use active substance
• Rapex
• Information on consumer incident
• Results from current suppervision
• Information from inspectors

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Thank you for your attention
Magdalena Noganska senior specialists
m.noganska_at_gis.gov.pl Chief Sanitary
Inspectorate Department of Environmental
Hygiene ul. Dluga 38/40 00-238 Warszawa phone.
(48) 22 536 1476 fax. [phone]