The final CLP compliance deadline for chemicals is fast approaching. Do you manufacture, supply or import hazardous substances into the EU? If so, you should be well aware, that by 1st June 2017 they must be classified, labelled and packaged according to the CLP (Classification, Labelling and Packaging of chemicals) regulations.
Before placing any chemical mixture on the market you must establish the potential risks they pose to human health and the environment and classify them in line with the identified hazards. Your mixtures must then be labelled in accordance with CLP so that workers and consumers are aware of their adverse effects before they handle them.
Why the changes?
The aim of the new regulation is to standardise the many different classifications and labelling standards used in different countries. This makes it safer to use and trade hazardous chemicals, not just within the EU, but worldwide, through the United Nations’ Globally Harmonised System – GHS. The aim is clear: one substance, one label – worldwide!
Many chemical substances and mixtures such as detergents, cements, paints, glues, dishwasher tablets, fertilizers, essential oils etc, as well as industrial mixtures, may have hazardous properties which can become a danger if they are not handled properly. 90-95% of all chemicals on the European market are preparations – i.e. mixtures of chemical substances (though most are not hazardous to health) and this will mean that a massive number of products will need to be re-classified and re-labelled in order to meet the new requirements.
Changes to classification under CLP
Under CLP there is a more subtle change in the way that blended (or diluted) products need to be assessed for classification; CLP places less emphasis on making simple calculations for mixtures of chemical substances and instead asks for greater ‘expert’ judgement.
To reclassify and label your substances the ECHA (European Chemicals Agency) has suggested the following tips:
- Use the information provided by your supplier in the safety data sheet (SDS)
- Check ECHA’s Classification and Labelling Inventory to find out how others have classified and labelled the relevant substances
- Make use of the harmonised classification and labelling for the most hazardous chemicals on the EU market
- Use the classification and labelling information from your suppliers if you refill, repackage or reimport hazardous chemicals into the EU without changing their composition
You will need to collate all the information you have on your product and assess its validity. You will then need to evaluate your information against the criteria for classification and work out the new classification. This may take someone with technical expertise because, in most cases, it is not simply a case of converting from the old classification to the new one. Be aware, that the calculation methods for some hazard classes have been modified and the concentration limits at which classification is needed may also have changed.
See the ECHA’s website for the full CLP Regulation (as well as other support materials). Helpful new classification pages lead you through the steps of the classification process and there are also useful links which will provide you with information and detailed instructions on how to fulfil your obligations and achieve CLP compliance.
Don’t forget to check the composition of all your mixtures, even those that did not have a classification under CHIP, because they may now need to be classified.
Finally, you need to re-label your product with the revised information and update any Safety Data Sheets that are provided to customers.
CLP compliance -Labelling
As well as changes in classification requirements, CLP introduces new pictograms, signal words and Hazard and Precautionary statements to labels to inform users of their hazards. For those substances and mixtures that are already on the market, there is an exemption from re-labelling and repackaging until 1st June 2017.
Elements that are required on a CLP label:
CLP Compliance – Packaging
CLP Regulations require that the packaging used for a chemical must:
- Prevent the chemical from escaping.
- Not be adversely affected by the chemical.
- Be strong enough to withstand normal handling.
If the package has a replaceable closure this must continue to prevent the chemical from escaping even after repeated use and some chemicals that are sold to the general public must be fitted with child-resistant fastenings and have a tactile danger warning (usually a small raised triangle) to alert the blind and the partially sighted that they are handling a dangerous chemical.
Safety Data Sheets
According to GHS, the Safety Data Sheet plays a prominent role in hazard communication so if you manufacture or supply chemical mixtures which contain hazardous substances, for professional or industrial use, then you must provide a Safety Data Sheet with your products to make all staff aware of how they must be handled, stored and disposed of.
SDSs must follow a 16 chapter format with the hazard information, including the labelling information, shown in section 2 (Hazard Identification). In the UK it is a requirement to include both the old CHIP and the new GHS classifications until the transition period that expires on 1st June 2015.
SDSs are governed by the REACH (Registration, Evaluation and Authorisation of Chemicals) Regulation, not CLP.
What do these changes mean for you?
If you supply a chemical, you should:
- Familiarise yourself what’s required from your organisation, before 1st June, and make sure you understand what your duties are under the new CLP Regulation.
- Cooperate with others in your supply chain, to make sure the changes are managed smoothly.
- Check that your chemicals are correctly classified and that your product labels are accurate.
If you use chemicals, you should:
- Look out for the changes and check that you are doing what is needed to use the chemical safely. If you are an employer, alert your employees to these changes too.
- Speak to your chemical suppliers if you have any questions or if you don’t understand the changes that have been made.
- If you are an employer, provide your employees with adequate information, instruction and training.
- Follow the advice provided and update workplace labels and Safety Data Sheets.
If you are unsure about your obligations, or need assistance with achieving CLP compliance, Hibiscus Plc can help; we’ve been printing labels and providing solutions for the chemical and hazardous goods industries for over 30 years.
We produce software for the classification and labelling of mixtures as well as Safety Datasheet Management software.
We also print standard and bespoke CLP labels for mixtures and can even supply tactile warning labels, handling and shipping labels and labels for transportation.
Contact us now, if you still haven’t made a full transition. The CLP compliance deadline is only months away.