Appendix 5

 

Background

 The Globally Harmonized System (GHS) for the Classification and Labelling of Chemicals is a United Nations initiative to facilitate international trade in chemicals, to promote standard criteria for classifying them according to their health, physical and environmental hazards, and to better inform users through standardised material safety data sheets (MSDS).

 The European Union (EU) has adopted GHS and will implement it in its member states as an EU Regulation, the Classification, Labelling and Packaging of Substances and Mixtures (CLP) Regulation.  

CLP entered into force in January 2009 and many parts of the CLP Regulation applied from 1 December 2010. For example, the classification and labelling requirements of CLP now apply to all single substances placed on the market, and those in the supply chain (e.g. on the shelves or in warehouses) on that date were allowed a two-year period of transition.

CLP will also apply to chemical mixtures from June 2015, again with a further two years grace to deal with products already in the supply chain.

Most of the responsibility for classifying, packaging and labelling according to CLP is placed on chemical suppliers, but end-users must be aware of the changes in labelling, phrasing and material safety data sheets (MSDS).

 Labelling

 The CLP Regulation requires chemicals to be classified for their hazards and labelled accordingly. Under CLP the labels are very different to the old scheme in the EU.

 The orange and black “hazard warning symbols”, familiar from the previous scheme, will be replaced by a white diamond edged in red with a black symbol or “pictogram” under CLP.

 Although some of the pictograms will be familiar (e.g. ‘skull’, and ‘flame’), three new pictograms have been introduced:

  • the ‘exclamation mark’, which indicates lower acute toxicity and irritation effects
  • the ‘silhouette’, which indicates serious, chronic health effects
  • the ‘gas cylinder’, which indicates gases under pressure.

There are a total of 9 pictograms under CLP and the three new ones are shown in the bottom row of the following examples.

Signage

   Burns skin signage

Burns skin

Damages eyes

Corrosive to metals

   Flammable sign

Flammable

Self-reactive, Self-heating

Pyrophoric

Emits flammable gas

Organic peroxide

 

 Explosive signage  

Explosive

Self-reactive

Organic peroxide

 Oxidiser signage

Oxidiser

 

 Acutely toxic signage

Acutely toxic

 

 Toxic to aquatic life signage

Toxic to aquatic life

 Acutely toxic - harmful - signage  

Acutely toxic (harmful)

Irritant to skin, eyes or respiratory tract

Skin sensitiser

 carcinogen signage

Carcinogen

Mutagen

Reproductive toxin

Respiratory sensitiser

Target organ toxicity

Toxic if aspirated

 Gas under pressure sign  

Gas under pressure

 

Phrasing

The familiar phrasing to describe hazards, ‘indication of danger’ in the old scheme (e.g. ‘Highly Flammable’, ‘Harmful’, ‘Dangerous to the Environment’) will change to a single ‘signal word’ under CLP (e.g. ‘Danger’ for very severe hazards or ‘Warning’ for less severe ones), unless deemed of such low hazard to not require one.

 Risk and Safety Phrases (R & S Phrases) are also being replaced by Hazard and Precautionary (H & P) Statements.

CLP comprises twenty-nine hazard classes and these are divided into three areas: physical, health and environmental hazards.

Each hazard statement has a corresponding code, which are separated as follows:

 H200s Physical hazards

  • H300s Health hazards
  • H400s Environmental hazards

CLP's hazard classes are further sub-divided into categories which have different criteria for classification.

For physical hazards, CLP has introduced new hazard classes, such as ‘corrosive to metals’. In doing so, it brings the classification for supply in line with the requirements for the transport of dangerous goods.

For health hazards, a chemical previously classified as ‘harmful’ may be classified under CLP according to its acute toxicity, aspiration toxicity, specific target organ toxicity – single or repeated exposure, i.e. ‘STOT SE’, or ‘STOT RE’, respectively. In addition, the transition to CLP may cause an apparent increase in hazard for some properties due to the classification criteria for the different CLP categories. In the case of acute oral toxicity, for example, a chemical previously classified as harmful may instead be classified as toxic under CLP.

Further information on the CLP classification system may be found on various suppliers’ websites, including:

http://www.sigmaaldrich.com/content/dam/sigma-aldrich/countries/european-images/GHS_EU_Poster.pdf

Material Safety Data Sheets (MSDS)

Under the transitional arrangements to adopt GHS material safety data sheets may provide health and safety phrasing information according to CLP as well the previous scheme. However, once the transitional period has lapsed only information relating to CLP will apply. This is currently the case with single chemicals.

However, as CLP will apply to mixtures from 1 June 2015, again with a further two years to deal with products in the supply chain, health and safety phrasing may be provided in both formats.

What do you need to do?

(a)  It is the responsibility of chemical manufacturers and suppliers to ensure that the labelling and classification of single chemicals is now fully CLP compliant. However, users should check that all new purchases are labelled appropriately.

(b)  Users should ensure that working stock bottles are labelled with the ‘new’ style labels (red diamond frame with the black hazard symbol), rather than ‘old’ style pictograms (orange and black diamond).

 (c)  You may still receive from suppliers chemical mixtures in containers labelled in the ‘old’ manner (until 1st June 2017). However, as this date approaches the number of chemicals labelled in the old format should reduce significantly. From this date all old hazard warning symbols will become invalid. Users should check that all new purchases are labelled appropriately.

 (d)  Some departments with a very small chemical inventory and a history of infrequent use should ensure that redundant chemical stock is safely disposed of (via the hazardous waste disposal route), and may then wish to replace any remaining chemical warning labels with CLP compliant ones. However, it is not expected that all current chemical stocks are relabelled, but certainly as existing stock is depleted and replaced users should ensure that all incoming chemicals are labelled in accordance with CLP. 

 (e)  COSHH assessments must be reviewed and updated to reflect the new H&P statements if the current risk and safety phrases indicate a lower standard of stringency, e.g. where ‘toxic’ chemicals were previously classified as ‘harmful’, or where H&P statements cross over multiple hazard classes. This review should consider whether any additional control measures are required, such as the need for health surveillance, or where changes are required to the way the work is conducted.

 (f)   COSHH assessments for all new work should use the information provided in H&P statements as the basis on which control measures are decided.

 (g)  If the H&P statements require an equivalent or lower level of stringency, existing protocols and SoPs, will most likely still be valid but they must be updated when the next review date is due. Documents can be updated immediately if preferred.

 (h)  Users are reminded of the importance of turning over their chemical stock, and disposing of those that are no longer required.

 Supervisors must ensure that these changes are brought to the attention of everyone involved in the work, and that progress is made to ensure that the requirements of CLP are phased in and fully implemented by the due date.