Clearly, classification of substances on the basis of human experience poses problems in classifying solutions that contain them. The regulations are deficient in terms of how to address such classifications. Use of scientifically based human toxicity estimates in a mixture calculation method seems to be the most valid approach. The relief provided by the ADR and RID, which, in essence nullifies human experience classifications, would seem to put those importing into Europe at a competitive disadvantage to those manufacturing solutions of "human experience" substances in Europe. It would seem that this issue is ripe for revisiting at the UNSCETDG, particularly in relation to methanol. In the meantime, those faced with the issue could seek out scientifically valid "human experience" data such as that noted for methanol above and use it as a basis for calculating a classification, when authorized. Who could reasonably challenge such an approach?
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