Special Report C&


M


Exactly what it says on the tin A closer look at classification, labelling & packaging of chemical products


From December 2010 there will be new ways in which chemical cleaning products must be labelled. Richard Webb, principal advisor for Exova’s non-food advisory division, looks at the changes which form part of the CLP Regulations as well as implications for manufacturers and end users of such products.


upon the assessment detailed in the MSDS.


Regulation No. EC 1272/2008 on the


Classification, Labelling and Packaging of Substances and Mixtures (the CLP Regulation) was put into force in all EU Member States on 20 January 2009, without the need for any national transposition (in other words that there was no need for member states to rewrite the regulations into their national law). The CLP Regulations pave the way for the implementation of the Globally Harmonised System (GHS) for chemical labelling within the EU. The first deadline (for classification and labelling of products consisting of a single substance) is 1 December 2010.


The CLP Regulations are one of the most complicated and technical pieces of legislation ever drafted, consisting of some 1355 pages, including annexes. Chemical cleaning products and detergents fall within the scope of these regu- lations if the substance or for- mulation is considered to be hazardous following assess- ment by a competent person.


Any hazards will be highlight- ed in the material safety data sheet (MSDS) and this should be prepared by product manu- facturers and provided to sup- pliers to end users for COSHH purposes. The CLP Regulations determine how the product should be labelled in terms of safety information and some- times how it should be packed, all of which is based


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The GHS system, which has already been agreed internationally, makes fundamental changes to the way in which chemicals must be classified and labelled. How products can be labelled - the facts


Risk and safety phrases will be amended, and the familiar orange and black hazard warning symbols will be replaced by modified red,


black and white versions. However, because the changes are considerable and will affect everyone who clas- sifies, packages, labels or supplies chemicals, the exist- ing Chemicals (Hazard Information and Packaging for Supply) Regulations (CHIP) have been amended to allow a transitional period under which chemicals can be assessed under either CHIP or CLP.


Products consisting of single ‘substances’ can continue to be classified and labelled in accordance with CHIP 4 until 1 December 2010. From that date, they must be classified and labelled under CLP. There is a transitional period for products placed on the market before 1 December 2010 which allows their continued sale (without relabelling or packaging) until 1 December 2012.


Products consisting of a ‘mixture’ of substances can continue to be classified and labelled in accordance with CHIP 4 until 1 June 2015. From that date, they must be classified and labelled under CLP. There is a transitional period for products placed on the market before 1 June 2015, which allows their


continued sale (without re- labelling or packaging) until 1 June 2017.


Up until these dates, there is a derogation allowing products to be packaged and labelled under CLP rather than CHIP 4 (to allow a ‘phase-in’ of new labels), although this is subject to a requirement that they are classified under both sets of regulations (in material safety data sheets, etc).


The French government has identified 86 substances that have been subject to changes in concentration limits which may result in their classification in mixtures being changed with


immediate effect. In the case of at least 39 of the


substances, the changes will result in a higher risk classification.


Compliance - what it means for manufacturers and end users


The onus for CLP compliance is with the manufacturers of chemical cleaning products (or importers if the product is made outside the EU). However, any businesses within the supply chain should be aware that labelling and packaging changes from CHIP to CLP is on the horizon. The immedi- ate concern is for businesses to ensure that products they supply and use are supported by a current MSDS following the format prescribed by the EU Registration Evaluation Assessment and authorisa- tion of Chemicals Regulations 2007 (REACH). Although the transition to CLP compliance should not be too costly for manufacturers, end users of chemical cleaning products might still see a price increase in products they use. This is more likely to be due to the potential restrictions on raw materials placed upon manu- facturers by the continuing demands of REACH. www.exova.com


There’s more to us than our smell


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