Have ELiquid Suppliers only months till their products are suspended.????

[pillbox38]

On Monday i had a visit from Trading Standards. It was partially at my own request as i had wanted clarification on issues regarding CHIP regulations relating to the nicotine fluid in the cartridges..I also wanted clarification on discrepancies in what one trading standards officer would recommend to what the next would.


Anyway as things transpired i showed him a bottle of wicked..Thinking that i had met most of the criteria required for CHIP compliance...

Most definetely i was in for a shock his recommendation was i re-call all bottles and stop selling immediately.. The rationale....

Nicotine as we know is classed under Chip as a Very Toxic substance. Ok i knew that, as yet till either myself(which i am in the process of doing) or trading standards test the fluid it is yet not proven that over 0.1% of the substance is raw nicotine..Of course it probably is, but untill an accredited laboratory says so it is not definite.

So this now will be the criteria, every bottle needs two 10mm by 10mm hazard signs on, at least 6 seperate toxic warnings, a braille label for blind or visually impaired user.

And more a full instruction sheet, full breakdown of toxicity levels. Full directions for the user re advice if feeling ill etc.

A childproof cap that meets the designated british standards, this needs proving by the manufacturers bottle cap tests to show this must be documented and ready to be produced if neccessary.

And trust me there is more


So i am on it but supliers better move fast or your fluid will be yanked...GUARANTEED>

 

[Mr.Darcy]

im not in the least bit surprised...

 

[pillbox38]

Now imagine if the cartridges are deemed to need to be CHIP compliant...


That would be one serious headache..How do you add a childproof cap or braille warnings on a cartridge???Not easy..

 

[baalel]

You would have to sell the carts in a childproof container, rather than making the carts childproof themselves i would think.

I'm glad to see you are on top of the liquid issue and I too am not suprised.

 

[Kate]

There must be packaging options for cartridges like sealed wrappers, boxes and the like.

It's going to hit fast once trading standards get themselves co-ordinated. At least you are on the way to compliance and haven't been told that you can't import, store and sell toxic substances yet. If it's all down to packaging then it's not too bad, that just means a few pence on the price and the hassle of compliance.

 

[pillbox38]

Baalel, it starts to move the cost dispoportionately higher..If this came to pass there is a soloution but it would take a little working.

Friday i am taking the fluid and a selection of cartridges to an accreditted lab in Manchester..

First step is weigh the cartridge, then extract the fluid, re-weigh. You then have the fluid volume.. Next test the fluid in the cartridge for percentile amount of nicotine, work out the nicotine weight then divide by the cartridges overall weight.

Then cross my fingers that its less than 1000 of a %.. If it isnt...No fluid filled cartridges will be sold in the UK.

This is a reality..

 

[pillbox38]

guichett - 31999L0045 -


Theres the link Kate its all in there, but a nightmare to dechiper..

 

[pillbox38]

Kate there is more any supplier not registered for the new REACH initiative on importation of chemicals by the first of January will be asking for trouble...

Regulations now i am in to them are a serious nightmare..Not insurmountable but take some doing..The reach form is huge..

We have employed a private health and safety consultant to guide us..Uptill 4 weeks ago i was ignorant of REACH..

 

[Kate]

Eeeeeewwww the regulations sound like hard going, good luck with it.

If you can't sell loaded cartridges then a way to do it would be to sell empty carts and separate eliquid in proper packaging. Not ideal for newbies and you might have to sell syringes too but it's better than a ban. Freesmoke send out groovy little foam cartridge holders to make refilling easier, it's just a piece of foam with four holes going through it that holds the cart upside down while you fill it. That might be something to look at selling too if we're all going to have to use bottles instead of filled cartridges.

For someone as well prepared as you Pillbox this is an opportunity, it could stop your UK competitors from selling if they can't get sorted quickly.

 

[baalel]

...
Then cross my fingers that its less than 1000 of a %.. If it isnt...No fluid filled cartridges will be sold in the UK.

..

Just to confirm, you actually mean 1/1000 of a percent ie 1/100000 of the mass of the total cart rather than 0.1%

baalel

 

[pillbox38]

baalel>>>I mean 1000 of a % of the overall single cartridge weight packaged..It is pretty unclear on specifics so until told otherwise my presumption is that. Also i might weigh or get the lab to weigh a 5 piece box, this then adds the weight of the cardboard. Same with a 50 piece box.

Kate>>> Your correct thats one soloution and i will comply, no other choice do it or shut up shop..That i wont allow...Sounds cocky but a fact...

 

[dc2k08]

guichett - 31999L0045 -


Theres the link Kate its all in there, but a nightmare to dechiper..

i pity anyone who has to read that.

 

[baalel]

from the Ruyan report http://healthnz.co.nz/RuyanCartridgeReport21-Oct-08.pdf it would look like an 18mg cart contains 1 ml of liquid charged, which would imply 18mg of nicotine. A full cart would need to weigh 1800g to have only 1/1000 of a percent nicotine content.

 

[dazzer1975]

Like others, this is no surprise, and I keep my fingers firmly crossed that pillbox can get on top of these requirements and make a living out of it to boot, if that is achievable, every one is a winner...

good work pillbox on organising yourself, getting informed and working towards ensuring a viable business with all the proper checks and balances.

 

[Grenage]

Hat's off to you for finding out potential problems by taking it to them, rather than them coming to you, Pillbox.

 

[pillbox38]

Thanks Dazzer..

Baalel... Im not sure your correct there, on our initial lab tests the nicotine content of an 18mg wicked fluid was approx 9%.

Lower for our cartridges...That is 9% remember of the weight of the fluid, there is minimal fluid in a charged pre packed cart..I think it will be a close call.If it is 9% by volume weight of the overall soloution, then the pre packed cartridge plastic and packaging has to weigh 100 times more.

I suspect three drops make up the fluid content..The weight of this fluid then gets divided by 10... This gives the nicotine content weight.. In comparison to 1 tenth weight of 3 drops of fluid a pre packed cartridge including plastic cap and cellophane wrapper and possibly the weight of the box divided by 5 gives the %.


I am guessing it might be ok..Or hoping

 

[baalel]

I'm just going by the table 2.2 in the Ruyan report. The 18mg number as far as I was aware was meaning 18mg/ml of the liquid and the Ruyan cart conyained 1ml of liquid (of which 0.9ml was vaporable)

if i am wrong I apologies, i'm not claiming any expertise

 

[threespeed]

Has anybody noticed if NICORETTE Nasal spray meets these regulations or are they just on a witch hunt

 

[pillbox38]

Nicorette is classed as a medicinal product therefore exempt...

 

[BarryK]

Has anybody noticed if NICORETTE Nasal spray meets these regulations or are they just on a witch hunt

I was told (by an PHCT 'Stop Smoking' councillor) that e-cigs were considered to be dangerous, as some of the ingredients have not been tested - Nicorette nasal spray is not dangerous as it 'contains only pure nicotine' - yeah, right........

I thought I'd take a look at the Health and Safety data sheeets for these products.

In the UK every product sold to the public that may contain dangerous substances, MUST - by law have Safety Data Sheets, showing contents risk etc.

These SDS's must be available to anyone purchasing or using the products.

Guess what? - there is no data anywhere, that I can find, showing what's contained within any of the officially recognised NRT products .................

pharmaceutical companies, they get away with murder, literally!

Good luck with all that BUMF pillbox, I don't envy you.....

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