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 Post subject: Re: We are winning!
PostPosted: Thu Apr 26, 2012 8:40 am 
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tommee wrote:
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The sixth amendment of 92/32/EEC? Since it is not part of the cosmetic requirements can you provide the reference to that 1 tonne requirement being changed perhaps? If not, I will understand that the assumptions are driving your views.


"Annex I of the Dangerous Substances Directive (DSD) ceased to have legal effect when CLP entered into force on 20 January 2009.

The list of harmonised substance classifications and labelling requirements were immediately incorporated into Annex VI of the CLP regulation. In Annex VI of REACH, the classification and labelling according to CLP is given in in Table 3.1 and that according to the DSD in Table 3.2. Amendments to this list are made through Adaptations to Technical Progress (ATP). "

http://www.reachready.co.uk/CLP_faq_free.php#harm

Anything else you require spoon feeding?


The portion of the CLP which no longer requires toxiciity testing would have been nice.

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 Post subject: Re: We are winning!
PostPosted: Thu Apr 26, 2012 8:41 am 
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Can you provided a link to data that supports that laws haven't changed? \:D/


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 Post subject: Re: We are winning!
PostPosted: Thu Apr 26, 2012 8:42 am 
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Wayne Stollings wrote:
tommee wrote:
Wayne Stollings wrote:
http://www.efma.org/PRODUCT-STEWARDSHIP-PROGRAM-10/images/1992-32EC.pdf

Article 8 section 4 gives the 1 tonne limit which triggers the requirements of Article 7 and which are specified in Annex VII.

I find no caveat related to or replacement of these requirements.


1992, moved on since.

Would help if you knew what you were talking about.


Where? According to the information I have found that was the seventh and last amendment to the 1967 base regulation. There seem to have been some annex additions, but I have found nothing that superceded the requirements of the articles referenced. Now if you can provide some link to such a change as has been asked prior, we can see what the current regulation is.


tommee wrote:
Go back to page 4.



Where on page 4 was there a mention of the change being discussed? Specific reference work much better if you actually have a point.

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 Post subject: Re: We are winning!
PostPosted: Thu Apr 26, 2012 8:43 am 
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tommee wrote:
Can you provided a link to data that supports that laws haven't changed? \:D/


No, as there is no way to provide such evidence of a negative proof.

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 Post subject: Re: We are winning!
PostPosted: Thu Apr 26, 2012 8:45 am 
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Wayne Stollings wrote:
tommee wrote:
Quote:
The sixth amendment of 92/32/EEC? Since it is not part of the cosmetic requirements can you provide the reference to that 1 tonne requirement being changed perhaps? If not, I will understand that the assumptions are driving your views.


"Annex I of the Dangerous Substances Directive (DSD) ceased to have legal effect when CLP entered into force on 20 January 2009.

The list of harmonised substance classifications and labelling requirements were immediately incorporated into Annex VI of the CLP regulation. In Annex VI of REACH, the classification and labelling according to CLP is given in in Table 3.1 and that according to the DSD in Table 3.2. Amendments to this list are made through Adaptations to Technical Progress (ATP). "

http://www.reachready.co.uk/CLP_faq_free.php#harm

Anything else you require spoon feeding?


The portion of the CLP which no longer requires toxiciity testing would have been nice.


Maybe a large box of baby wipes to wipe the egg off your face would be more appropriate?

Your spin is pathetic.


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 Post subject: Re: We are winning!
PostPosted: Thu Apr 26, 2012 8:46 am 
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Wayne Stollings wrote:
tommee wrote:
Can you provided a link to data that supports that laws haven't changed? \:D/


No, as there is no way to provide such evidence of a negative proof.


Ok, do you want me to provide you with a link that shows you what laws have changed..?


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 Post subject: Re: We are winning!
PostPosted: Thu Apr 26, 2012 2:03 pm 
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Wayne Stollings wrote:
tommee wrote:
Quote:
The sixth amendment of 92/32/EEC? Since it is not part of the cosmetic requirements can you provide the reference to that 1 tonne requirement being changed perhaps? If not, I will understand that the assumptions are driving your views.


"Annex I of the Dangerous Substances Directive (DSD) ceased to have legal effect when CLP entered into force on 20 January 2009.

The list of harmonised substance classifications and labelling requirements were immediately incorporated into Annex VI of the CLP regulation. In Annex VI of REACH, the classification and labelling according to CLP is given in in Table 3.1 and that according to the DSD in Table 3.2. Amendments to this list are made through Adaptations to Technical Progress (ATP). "

http://www.reachready.co.uk/CLP_faq_free.php#harm

Anything else you require spoon feeding?


The portion of the CLP which no longer requires toxiciity testing would have been nice.


tommee wrote:
Maybe a large box of baby wipes to wipe the egg off your face would be more appropriate?

Your spin is pathetic.


What spin would be involved in pointing out the link showing where toxicity testing was no longer required would have been nice?

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 Post subject: Re: We are winning!
PostPosted: Thu Apr 26, 2012 2:06 pm 
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tommee wrote:
Wayne Stollings wrote:
tommee wrote:
Can you provided a link to data that supports that laws haven't changed? \:D/


No, as there is no way to provide such evidence of a negative proof.


Ok, do you want me to provide you with a link that shows you what laws have changed..?


That would be nice and what I pointed out in the previous post as being a desired addition. Since there are several references to the toxicity testing in the regulations linked to the CLP showing where such testing is no longer required would be nice.

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 Post subject: Re: We are winning!
PostPosted: Thu Apr 26, 2012 2:44 pm 
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Wayne Stollings wrote:

That would be nice and what I pointed out in the previous post as being a desired addition. Since there are several references to the toxicity testing in the regulations linked to the CLP showing where such testing is no longer required would be nice.


Who said there weren't required? Are you now claiming the laws haven't changed, you really want it spoon feeding don't you? Pathetic.

http://www.leffingwell.com/cosmetics/vol_1en.pdf


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 Post subject: Re: We are winning!
PostPosted: Thu Apr 26, 2012 3:27 pm 
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tommee wrote:
Wayne Stollings wrote:

That would be nice and what I pointed out in the previous post as being a desired addition. Since there are several references to the toxicity testing in the regulations linked to the CLP showing where such testing is no longer required would be nice.


Who said there weren't required? Are you now claiming the laws haven't changed, you really want it spoon feeding don't you? Pathetic.

http://www.leffingwell.com/cosmetics/vol_1en.pdf


That was the point being made and the whole context of that portion of the discussion concerning toxicity testing on compounds which were used in other applications in addition to the possible cosmetic uses. You did understand the discussion on the multiple uses and the testing would be required for those uses?

The link you provided does not relate to the current discussion on the change in the CLP supposedly eliminating the need for toxicity testing.

I am beginnig to wonder if you have any idea of what has been said, but are running on pure assumptions.

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 Post subject: Re: We are winning!
PostPosted: Thu Apr 26, 2012 3:33 pm 
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Wayne Stollings wrote:
tommee wrote:
Yes it would help if you knew what you were talking about.

"Cosmetic products (until 2013)"

National laws applicable to cosmetic products are harmonised at European level in order to facilitate the free movement of these products within the European Union’s (EU) internal market. This Directive lays down rules on the composition, labelling and packaging of cosmetic products. It also introduces a ban on animal testing and on the marketing of products that have been tested on animals."

"ACT

Council Directive 76/768/EEC of 27 July 1976 on the approximation of the laws of the Member States relating to cosmetic products (Cosmetics Directive) [See amending act(s)].
SUMMARY

The free movement of cosmetic products within the European market cannot be restricted or prohibited by Member States if these products are not dangerous to human health under normal or foreseeable conditions of use.

However, if a cosmetic product conforming to this Directive constitutes a danger to human health, the Member State of the territory on which the product is marketed may take restrictive or prohibitive measures. In this instance, it informs the other Member States and the Commission so that appropriate measures can be taken throughout the European Union (EU).

Ingredients and composition

The Directive determines the list of substances which are prohibited in the composition of cosmetic products (Annex II) and the substances which are subject to restrictions or specific conditions of use (Annex III).

The Directive also contains lists of authorised colourings (Annex IV), preservatives (Annex VI) and UV filters (Annex VII).

Labelling

Containers and/or packaging must specifically mention, in indelible, easily legible and visible characters:

the name and address of the manufacturer or of the person responsible for marketing the product;
the nominal contents at the time of packaging, by weight or by volume;
the date of minimum durability indicated for products with a minimum durability of less than 30 months;
the period of time after opening for which the product can be used for products with a minimum durability of more than 30 months (indicated with the symbol representing an open pot of cream);
the function of the product and particular precautions for use;
the batch number.

This information must be in the official language(s) of the respective Member State.

Moreover, the labelling must contain a list of ingredients. Perfume and aromatic compositions are designated by the words "perfume" or "aroma", except where these have been identified as a significant cause of allergic reactions.

Market surveillance

Member States are responsible for monitoring their market. To this end, they check the safety of products manufactured or imported in the EU. Furthermore, they also ensure that the characteristics attributed to cosmetic products are not deceptive.

The manufacturer, the importer or the person responsible for marketing the product must inform the national competent authorities when a product is imported into the EU for the first time.

Animal testing

The Directive puts an end to animal testing by imposing bans on:

testing finished cosmetic products and ingredients on animals (testing ban);
marketing finished cosmetic products which have been tested on animals or which contain ingredients that have been tested on animals (marketing ban).

With regard to repeated-dose toxicity tests, reproductive toxicity tests, and toxicokinetics, the marketing prohibition applies from 11 March 2013. This prohibition is applicable regardless of the availability of alternative test methods."

http://europa.eu/legislation_summaries/ ... 191_en.htm

I do believe I've already linked this..


It is supposed to have done what? Indicate the EU regulations do not currently require toxicity testing for products/ingredients which may be used in cosmetics? Wrong, the general statute does, even for cosmetics as it is not prohibited from said requirement. The testing cannot be required to have been performed solely for cosmetic use within the EU, but the general statute requires everything reasonably suspected of harm to be properly tested, which would include toxicity testing since it is by definition reasonably suspected and is not prohibited by any other regulation. This may change in some fashion in the future, but presently it is the law.


So, if you can show where toxicity testing is no longer required for products sold in the EU you will have made a point .... if not you will have performed on a par with your peers.

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 Post subject: Re: We are winning!
PostPosted: Fri Apr 27, 2012 4:16 pm 
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Quote:
Maybe a large box of baby wipes to wipe the egg off your face would be more appropriate?

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 Post subject: Re: We are winning!
PostPosted: Sat Apr 28, 2012 6:49 am 
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Wayne Stollings wrote:
Quote:
Maybe a large box of baby wipes to wipe the egg off your face would be more appropriate?



Haven't finished with you yet, got more important things in life to be doing at the moment.

Maybe you should tell me why government statistics for UK state 0 animals used in cosmetic testing..? And maybe you should read up on why the 1 tonne was implemented :-

Pathetic.


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 Post subject: Re: We are winning!
PostPosted: Sat Apr 28, 2012 6:54 am 
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Wayne Stollings wrote:
tommee wrote:
Wayne Stollings wrote:

The sixth amendment of 92/32/EEC? Since it is not part of the cosmetic requirements can you provide the reference to that 1 tonne requirement being changed perhaps? If not, I will understand that the assumptions are driving your views.



Production volumes of 1 to 10 tonne requires toxicology test for carcinogenic, mutagenic or reproductive effect, the test required a mutagenicity test in bacteria....

Any thing else you require?

Would help if you knew what you were talking about



Where is the change to OR instead of and for this requirement? Annex VII clearly states all are required in the report.

4.1 Acute toxicity - two routes of exposure
4.3.1 Mutagencity - two tests one of which is bacteriolical for reverse mutation
4.3.2 screening for toxicity related to reproduction
5.1.1 Acute toxicity for fish
5.1.2 Acute toxicity for daphnia


"Annex VII A, VII B, VII C, VII D and Annex VIII are deleted by Directive 2006/121/EC with effect from 1 June 2008."

http://europa.eu/legislation_summaries/ ... 276_en.htm

More egg on thy face.....

Helps if you know what you are talking about.


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 Post subject: Re: We are winning!
PostPosted: Sat Apr 28, 2012 7:29 am 
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Wayne Stollings wrote:
tommee wrote:
Wayne Stollings wrote:

The sixth amendment of 92/32/EEC? Since it is not part of the cosmetic requirements can you provide the reference to that 1 tonne requirement being changed perhaps? If not, I will understand that the assumptions are driving your views.



Production volumes of 1 to 10 tonne requires toxicology test for carcinogenic, mutagenic or reproductive effect, the test required a mutagenicity test in bacteria....

Any thing else you require?

Would help if you knew what you were talking about



Where is the change to OR instead of and for this requirement? Annex VII clearly states all are required in the report.

4.1 Acute toxicity - two routes of exposure
4.3.1 Mutagencity - two tests one of which is bacteriolical for reverse mutation
4.3.2 screening for toxicity related to reproduction
5.1.1 Acute toxicity for fish
5.1.2 Acute toxicity for daphnia


tommee wrote:
"Annex VII A, VII B, VII C, VII D and Annex VIII are deleted by Directive 2006/121/EC with effect from 1 June 2008."

http://europa.eu/legislation_summaries/ ... 276_en.htm

More egg on thy face.....

Helps if you know what you are talking about.


Helps more to provide references to your statements so one does not have to guess, but since we moved past that particular reference days ago it seems you are more than a day late and a dollar short.

When you finally catch up to the discussion let me know,

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