The EU is not the UN

The EU is not the UN

Not so much a blog post, more a rant with a sting in the tail ...

Unlike USA since GHS became a thing, Brussels seems keen to go its own way. Admittedly and not to mention its recent isolationism, Washington doesn't like funding a number of UN activities, but America still seems to be conforming with the UN Purple book.

Europe on the other hand seems intent on going beyond GHS in some areas.

Europeans legislate - Americans litigate

America has some tighter classification cutoffs - at least in California - whereas Brussels has banned products such as anti-freeze containing alcohol to prevent people poisoning themselves. In USA a lawyer would be happy to litigate on behalf of your estate - if you left one after consuming anti-freeze.


I suppose as soon as you mention Brexit you have lost the argument. Diverging momentarily, neither side of the Brexit argument is entirely correct but, in my opinion Brussels exercises its power too readily. It feels paternalistic. I can understand why the adult half of UK wants out.

It is also plain to me that Brexit will prevent my jumping on a train from London to Paris without second thoughts.

A global industry needs globally agreed legislation to govern health and safety - especially when laws of physics are the ultimate authority.

So my major problem with Brussels is that they won't try to change things from inside the UN committee for the Purple Book. They just blast away with their own regulations. My main problem with Brexit is the UK gave up trying to improve the EU from within.

On balance I think they are both wrong but in Europe, Brussels is all powerful and therefore more wrong.

Unique Formulation Identifier - UFI

UFI is a Brussels initiative. I haven't seen any such proposals within Purple Book committee proceedings. There may have been some but I certainly haven't noticed them.

It starts in 2020 and becomes mandatory in 2025.

Target audience is poisons centres. The cost of complying falls entirely on the chemical industry. In my opinion this is a flawed initiative for 2 reasons and one consequence:

  1. In only one corner of the global market, and with no global consensus, UFI will result in the global chemical industry handing over information to EU poisons centres. That will be an expense with no balancing revenue
  2. As soon as the information is handed over and disconnected from its curated source it will be immediately orphaned and go stale
  3. Out-of-date information is worse than useless

Act local think global

The EU is doing the opposite. They are messing with a global industry while scratching a local itch. There is a notion that power corrupts. Brussels is all-powerful in Europe and that seems to blind it to any higher authority. Speaking for myself, I deplore the concept of unilateral UFI for Europe only.

It would be admirable if European chemical experts and European medical emergency experts had enlisted the collaboration of their global peers. They should have done that, argued their way to consensus and then proposed it to the Purple Book UN committee.

Sting in the tail

Having said all that, UFI has just been rolled out in SharedSDS.

No-one can do anything about UFI being mandatory in Europe and probably UK so we had to bite that bullet. However, we have solved the global corner problem and definitely avoided the above-mentioned consequence.

  1. SharedSDS automatically generates a valid UFI for any substance or mixture if the SDS wrapper is for a region covered by the UFI regulations. That currently includes UK.
  2. SharedSDS has a base licence which authorises licensing of legitimate Emergency Services for access to the information required by the EU regulation but subject to liquidated damages of US$20m if data secrecy is breached. See ESO licence.
  3. Naturally, SharedSDS by design prevents disconnection from curated data.

Current rating: 5