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The black list H phrase criteria should be based on labeling information in the safety data sheet, not H-phrases entered in the risk assessment. If other phrases have been entered in the risk assessment these should be taken into account as well.

Often you wish to start using search lists and search functions before making the risk assessments. Maybe to sort out the "worst" products. If a company that has not done their risk assessments yet creates a black list and makes a search they will think that they have no black listed products. Customers might not read the information about the blacklist criteria. 

If nothing else can be done, at least there should be a warning/info box saying that the risk assessment must be done prior to using the black list.