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FEATURE Security


Changes ahead for the packaging of hazardous materials


Be prepared as a new system for classifying and labelling chemicals comes into force next month, which will see new ways for these products to be handled


A new set of requirements for the handling and labelling of chemical products is coming into force next month, which will see some substances coming under the Control of Major Accident Hazards (COMAH) for the first time. Neil Howe, senior legal author with online health and safety legislation specialists, Cedrec, explains more.


The Classification, Labelling and Packaging of Substances and Mixtures Regulation 2008 (CLP Regulation) established a regulatory framework for the classification and labelling of substances and mixtures in the EU, and began to


come into force in 2009. This is based on an international agreement known as the Globally Harmonised System (GHS).


New labels to be used The CLP Regulation requires chemicals to be classified for their hazards and their packaging labelled accordingly. This involves different labels to those under the outgoing regulatory framework, and a new set of hazard pictograms has been established to advise people handling materials. The phase-in of this has been gradual to ease the burden on business. CLP impacts on all aspects of chemicals' legislation, from REACH to COSHH, but one development will be how it relates to the newly published COMAH Regulations 2015. Both come into force on June 1 2015. The COMAH directive applies to any business where dangerous substances are either present on-site above the threshold quantities or could be generated in the event of an accident. The major change involves the re-classification of chemicals to align them with GHS. Organisations will be in scope under COMAH if they store or use a dangerous substance over one of the thresholds. Those who find themselves reassigned to a


higher category tier will need to prepare a safety report at least every five years, but more frequently in the event of any major changes, which might compromise the safety of people and the environment. New additions under COMAH and CLP include pyrophoric liquids and solids and flammable aerosols. With the latter being a new category, many companies - particularly warehousing, logistics and distribution operators - could find that they suddenly fall under COMAH legislation.


Prepare for the change June is not far away, so its vital companies who store and use dangerous substances check if their COMAH status is likely to change. SMEs who find themselves now in scope of COMAH are likely to feel the financial burden of legislation more than larger companies, since the effect will be greater. Changes in the quantities of substances/combinations of substances might also mean that companies further down the supply chain become caught up in COMAH legislation, for example storage and distribution companies, if the quantities fall below those they currently handle. So the message is simple: prepare now and be ready for change.


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36 May 2015


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