REGULAR
We’re Going Through Changes
In this month’s column, Matt Baines, of Premiere Products, discusses the new CLP regulations that will be coming into effect in a few months, and what they will mean to fellow chemical manufacturers.
Having looked back at my recent contributions to this magazine, I am struck by the frequency with which I reference the subject of change and specifically the changes I have witnessed in my numerous years in cleaning.
You might be forgiven for misinterpreting this as some kind of inherent fear or reluctance to change. However contrary to this, I believe that I approach most change with a cautious optimism.
Having said this there is one impending change to regulation that is as fundamentally significant in the arena of cleaning chemical manufacture as any I have ever seen.
I am talking about the Classification, Labelling & Packaging Regulation (CLP). CLP first came into force on 20th January 2009 in all EU Member States, including the UK. However 1st June is the “line in the sand”, by which time all newly manufactured products will need to comply by law.
CLP is the method of classifying and labelling chemicals under the United Nations’ Globally Harmonised System (GHS) and is born out of some fairly common sense ideology – that chemical classifications should be universal so that, for example, products that are imported or exported from one country to another carry a classification that is both understandable and relevant in both locations.
In the UK we are changing to CLP from the Chemicals (Hazard Information & Packaging for Supply) Regulations (CHIP). The CHIP reg’s have served us well since 1993
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and for many of us are so ingrained that it will take a good deal of re- education to ensure that the change is seamless and doesn’t throw up any unnecessary concern.
So what is it that will actually be changing?
In very basic terms the two most obvious changes are to the pictogram warning symbols themselves and to the accompanying explanatory phrases.
Orange square pictograms are changing to red diamonds and whilst some new pictograms have been introduced, a number remain similar in appearance to their predecessors.
Risk & Safety phrases (R&S) are also changing to Hazard (H) and Precautionary (P) statements.
These alterations can at first glance appear to be fairly cosmetic. However the most essential factor to understand is that the method of calculating classification is much stricter under CLP than it was under CHIP. We will see many more products being required to carry warning symbols than ever before.
Having become accustomed to CLP over the last year or so I would also add that it requires a change of mindset when undertaking assessments on the chemicals being sold, purchased or used. Under the CHIP regulations we had all become used to seeing a symbol and immediately understanding what level of risk was associated with it.
By contrast under CLP the warning pictogram notifies us of the level of risk whilst the hazard and
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precautionary statements detail the specifics.
Denotes Warning (implying less severe hazard)
Denotes Danger (implying more severe hazard)
Given that the pictogram for Danger is very similar under CLP as that used for Corrosive under CHIP, awareness and understanding are critical here in order for confusion to be avoided.
Material Safety Data Sheets will also be updated in order to reflect the change and our end user customers are being advised to update their Risk and COSHH Assessments as soon as they are to be in receipt of newly labeled products. Whilst the product inside the bottle is not changing, the regulation has caused new classifications and these need to be reflected therein.
Biased though I am as a chemical manufacturer employee, I can understand the need for a universal system and I appreciate the motives of the “powers that be” in raising safety thresholds in order for people to be safer. However the regulation certainly has its imperfections and it is incumbent on manufacturers to ensure that our distributor partners and end users are provided with the correct advice, information and training to ensure that their current and future product selection continues to serve them as well as it always has.
www.premiereproducts.co.uk
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