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REACH June 2015 SVHC - Verdict error in WPA

rks
Newbie

REACH June 2015 SVHC - Verdict error in WPA


Reach SVHC June 2015 release added two substances for which CAS number is not defined unlike the other substances.

Currently WPA is checking for the string 5-sec-butyl-2-(2,4-dimethylcyclohex-3-en-1-yl)-5-methyl-1,3-dioxane [1], 5-sec-butyl-2-(4,6-dimethylcyclohex-3-en-1-yl)-5-methyl-1,3-dioxane [2][covering any of the individual stereoisomers of [1] and [2] or any combination thereof] to determine a PASS or FAIL for the substance.

ECHA as part of the REACH notification has given the below clarification.

  Candidate list entry “5-sec-butyl-2-(2,4-dimethylcyclohex-3-en-1-yl)-5-methyl-1,3-dioxane [1], 5-sec-butyl-2-(4,6-dimethylcyclohex-3-en-1-yl)-5-methyl-1,3-dioxane [2] [covering any of the individual stereoisomers of [1] and [2] or any combination thereof]”, is a group entry covering substance [1], substance [2], any of the individual stereoisomers of substance [1], any of the individual stereoisomers of substance [2], and any combinations of these substances. Therefore, if a part contains only substance [1] or only substance [2], these  still fall within this group entry and the Candidate list obligations
apply.

Section 1.2 of the corresponding supporting document provides examples of substances belonging to this group for which a registration or C&L notification is available. The supporting document for this Candidate list entry is available at: http://echa.europa.eu/documents/10162/b33a9276-9a0e-4720-87ce-76dc651a6ee6

   Table 2 of the same supporting document section provides a non-exhaustive list of examples of substances covered by this group entry.

Suggestion

Based on the above logic, system should be doing the check based on [1] OR [2] and by the presence of ANY one of the substance mentioned in the ECHA release and NOT by the enitir string alone