Globally Harmonised System and CLP Regulations
The UN Globally Harmonised System aims to make all classification etc of substances harmonised the world over to reduce confusion and aid risk reduction measures.
This system was implemented in the EU by the Classification, Labelling and Packaging of Substances and Mixtures Regulation (CLP Regulation) which came into effect 20 January 2009, subject to a lengthy transitional period, see table below. Prior to this harmonisation, substances and preparations were classified, labelled and packaged according to the Chemicals (Hazard Information and Packaging for Supply) Regulations 2009 (CHIP).
Most of the onus is on the Suppliers with regard to CLP but end-users will need to be aware of the changes in phrasing, pictograms and safety data sheets.
Regulations update for some hazardous substances
Update on the Classification, Labelling and Packaging of Substances and Mixtures Regulation (CLP), the Chemicals (Hazard Information and Packaging for Supply) Regulations 2009 (CHIP) and the Health and Safety (Safety Signs and Signals) Regulations 1996.
The deadline for the full implementation has now passed.
Dates below are now for reference purposes only:
|Date||Change||Explanation for end users|
|1st December 2010 – 1st June 2015||Suppliers must classify substances according to both CHIP and CLP. They must label and package according to CLP||Classification of substance by Suppliers will be undertaken with reference to CHIP and the new CLP. All labelling and packaging of these substances must be according to CLP.|
|1st June 20015 onwards||Suppliers must classify, label and package according to CLP.||All classification, labelling and packaging will be undertaken with reference to CLP. CHIP will no longer be used.|
|Date||Change||Explanation for end users|
|1st December 2010 – 1st June 2015||Suppliers must classify preparations according to CHIP, and may continue to label and package them according to regulations 6 to 11 of CHIP. However they may as an alternative choose to classify, label and package mixtures according to CLP. In this case, they must continue to classify in addition under regulation 4 of CHIP, but the requirements on labelling and packaging in regulations 6 to 11 of CHIP no longer apply.||Classification of mixtures by Suppliers may be undertaken with reference to CHIP and the new CLP. If CHIP alone is used, then CHIP labelling and packaging must still be used. If CHIP and CLP is used, then the mixture must still be classified under CHIP but labelled and packaged under CLP.|
|1st June 2015 onwards||Suppliers must classify, label and package according to CLP.||All classification, labelling and packaging will be undertaken with reference to CLP. CHIP will no longer be used. NB mixtures already in the supply chain by 1st June 2015 have an extended transition deadline of 1st June 2017.|
What is different?
The word ‘Preparation’ has been replaced with the word ‘Mixture’.
There are now only 9 pictograms, all a white background with a red diamond frame with the black hazard symbol inside. All pictograms relating to transport are still governed by the Transport of Dangerous Goods Regulations.
A pdf list produced by the UNECE can be viewed below or on the Sigma Aldrich website.
Each substance will now have either ‘Danger’ or ‘Warning’ on the label, unless it is deemed of such low hazard to not require one.
- Danger = more severe hazards
- Warning = less severe hazards
Standard statement about the nature of hazard and degree of hazard of the substance. Each hazard statement has a corresponding identification code, however this may not be used instead of the written hazard statement on the packaging/safety data sheet and must only be used for reference.
A full list of hazard statements produced by the EC is available below as well as on the Sigma Aldrich website.
Brief statement to provide measure to undertake to minimise or prevent effects from physical, health or environmental hazards. These include first aid measures and can be a pictogram (see above) or a written statement.
A full list of precautionary statements produced by the EC is available below as well as on the Sigma Aldrich website.
Risk and Safety Phrases?
The hazard and precautionary statements replace all risk and safety phrases which will no longer be used. A full list of risk and safety phrases converted into hazard and precautionary statements is on the EC GHS website.
Any guidance on this website which refers to risk and safety phrases will be updated with hazard and precautionary statements in due course. All pages will contain the following guidance;
Any risk and safety phrases directly replace by hazard and precautionary statements have been added in brackets above. Some risk and safety phrases may not have been replaced and therefore have no corresponding hazard or precautionary statements.
Safety Data Sheets:
The word ‘material’ has been removed and these are now known simply as Safety Data Sheets. They must include 16 set headings;
- Hazard(s) identification
- Composition/information on ingredients
- First-aid measures
- Fire-fighting measures
- Accidental release measures
- Handling and storage
- Exposure controls/personal protection
- Physical and chemical properties
- Stability and reactivity
- Toxicological information
- Ecological information
- Disposal considerations
- Transport information
- Regulatory information
- Other information
Full details are available on the UNECE website.
All labels of substances must conform to the GHS via the CLP. Examples are given on the ECHA website with full details on the UNECE website.
Classification & Labelling Inventory:
The Approved Supply List will be replaced with the Classification and Labelling Inventory. This is a database that will contain basic classification and labelling information on notified and registered substances received from manufacturers and importers. It will also contain the list of harmonised classifications. The Inventory will be established and maintained by ECHA.
The full list of the ASL is now contained in Table 3.1 of Annexe VI of the CLP Regulation published on the European Commision website
How does this affect me?
End-users will start to take receipt of substances with the new packaging from 1st December 2010 and therefore this information should be brought to the attention of all staff and students who may come into contact with such substances and/or mixtures. Any substances already in the supply chain (already on the shelf) do not need to be updated to reflect the CLP until 1st December 2012 (mixtures until 1st June 2017). In effect you will still be supplied with substances packaged in the ‘old’ style. There is no explicit requriement to re-label any current stock, however you may wish to re-label your current stock with the new system from 1st December 2010 to make sure users become accustomed to the new system and that old stock is treated in the same manner as new stock.
Guidance states that all containers should maintain the suppliers’ label. However, if you do decant into smaller containers and these are too small to usefully hold the information required, this information can be published in another manner deemed suitable, for example on a poster next to the cabinet in which the container is kept.
In the interim period until all deadline have passed, you should use the new CLP system of labelling but you may also wish to retain the 'old' labelling to ensure users have all the information at hand they require to work safely.
What about my COSHH risk assessments?
You should not have to re-do your COSHH risk assessments because of this new system. All risk or safety phrases will be replaced with equivalent or less severe hazard or precautionary statements. The current COSHH form ( previously known as HS1 and HS2 but replaced early 2012 with one form) on the Health and Safety Department has been updated to refer to hazard and precautionary statements as well as to risk and safety phrase until all substances have met the ultimate deadline of 1st June 2015. If you use any local variants of these forms, please update them with the new statements. To check the new hazard and precautionary statements against the old risk and safety phrase, please use the translation table below.
What about my cabinet, do I need to update the risk and safety phrases on this?
Yes, you should, in the short term, put both risk and safety phrases as well as hazard and precautionary statements on the cabinets your substances are stored in. Until full compliance has been reached, you may still take receipt of containers labelled in the ‘old’ manner (substances until 1st June 2012, mixtures until 1st June 2017) and you will most likely still have containers bought previously with the ‘old’ style labels. You should also replace the ‘old’ style pictograms (orange and black diamond) with the ‘new’ style (red diamond frame with the black hazard symbol). Downloadable pictograms are available on the UNECE website.
You can also order GHS compliant pictograms and posters from any good laboratory goods supplier.
The Storage of Hazardous Substances guidance published by the Health and Safety Department will not change in respect of the CLP Regulations as the guidance is based on the transport classification and signage which have not changed.
Does my Safe System of Work need changed?
This should be updated to reflect any new hazard and precautionary statement if the current risk and safety phrases are at a lower standard. If, however, the hazard and precautionary statements are at an equivalent or lesser level, your SSoW will still be valid and can be updated when your next periodic review is due. You can of course review all your SSoW and update them now if you wish.