Health & Safety Department

UK CLP Regulations

The UN Globally Harmonised System (GHS) aims to make all classification etc of substances harmonised the world over to reduce confusion and aid risk reduction measures. Since the 1st January 2021, the EU CLP has now been implemented as the UK CLP.

The GHS 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 (all deadline have now passed). 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).

2021 update

The EU CLP Regulation as amended, is retained in GB law. These arrangements mean that we will continue to adopt GHS, independently of the European Union.

The content below explains the changes as they were implemented by the original EU CLP Regulations, which are still current in the UK CLP. Some important points to note with UK CLP:

  • the main duties to classify, label and package remain
  • HSE becomes the relevant GB CLP Agency overseeing GB CLP functions for substances and mixtures placed on the GB market
  • the GB CLP Regulation applies to GB-based manufacturers, importers, downstream users and distributors supplying the GB market
  • HSE becomes the relevant GB CLP Agency overseeing GB CLP functions for substances and mixtures placed on the GB market
  • the classification and labelling of substances and mixtures placed on the GB market must comply with GB MCL where relevant. GB MCLs are listed in the GB mandatory classification and labelling list at https://www.hse.gov.uk/chemical-classification/assets/docs/mcl-list.xlsx

A full list of changes to note are at https://www.hse.gov.uk/chemical-classification/legal/clp-regulation.htm

UK CLP explained

Basic terminology:

The word ‘Preparation’ has been replaced with the word ‘Mixture’.

Pictograms:

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 can be viewed below on the Sigma Aldrich website.

Signal words:

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

Hazard statements:

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.

Precautionary statements:

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. 

 

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;

  1. Identification
  2. Hazard(s) identification
  3. Composition/information on ingredients
  4. First-aid measures
  5. Fire-fighting measures
  6. Accidental release measures
  7. Handling and storage
  8. Exposure controls/personal protection
  9. Physical and chemical properties
  10. Stability and reactivity
  11. Toxicological information
  12. Ecological information
  13. Disposal considerations
  14. Transport information
  15. Regulatory information
  16. Other information

Full details are available on the UNECE website.

Labels:

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.

How does this affect me?

As the EU CLP have been retained as the UK CLP, there should be no immediate effect to the University community, apart from taking note of the changes already highlighted in the bulleted list above.

What about my COSHH risk assessments and Safe System of Work?

You should not have to re-do your COSHH risk assessments or Safe System of Work because of this change.