The latest article »Can we generate a new unique formula identifier (UFI code) ourselves?« has sparked quite a few responses. Therefore, today I want to clarify once again what an "empty" UFI code or "empty" UFI identifier means. This was one of the most common questions.
The UFI code is "empty" if no PCN notification has been submitted for it and no mandatory reporting of data on the hazardous properties of the mixture has been made to the poison centre.
You should be aware that a UFI generator is just a tool that allows you to obtain a UFI code. This does not mean that the generator checks whether this particular UFI code is linked to a specific PCN notification and whether it has been successfully implemented at all.
Let us now look at a concrete example with the consequences of using an "empty" UFI code.
You assign an “empty” UFI code to your mixture and put in on the label. It is, therefore, a UFI code without a PCN notification. Let’s say a formulator (downstream user) wants to use your mixture as a mixture in mixture (MiM). Information about your mixture has not yet been provided and therefore the formulator is dealing with an "empty" UFI code found on your label which the formulator would now like to use in PCN notification of its mixture.
But an "empty" UFI prevents the poison centre from establishing a link to all information about the mixture. This prevents faster and more efficient first aid, which was one of the key goals of establishing such a UFI/PCN procedure.
Therefore, the formulator (a downstream user of your mixture that uses it as a raw material) can not use your UFI code when performing PCN notification of its mixture because it is "empty". Your "empty" UFI code can not be referenced in the PCN notification process. To be able to successfully perform a PCN notification for its mixture, you must inform the formulator of the 100% composition of your mixture.
To avoid this, the best solution is not to generate an “empty” UFI code, but to perform a full PCN notification for your mixture. In this case, you do not need to communicate 100% of the composition of your mixture to the formulators who use your mixture to produce new mixtures.
If you do not know where to start or do not have the time to perform this PCN notification efficiently and correctly (and also update it), it may be time to contact me at simona@bens-consulting.
Just contacting me costs you absolutely nothing - but it can save you a lot of trouble in January 2021.