CLP update

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

CLP and CHIP

As you should know, the Classification, Labelling and Packaging of Substances and Mixtures Regulation (CLP) were introduced with a phased implementation from 2010 until 1st June 2015 * and has replaced the Chemicals (Hazard Information and Packaging for Supply) Regulations 2009 (CHIP) which has now been repealed in its entirety.

Guidance on the phased introduction has been on our website for quite some time and you may wish to review this guidance again now that the deadline has passed.

* With the exception of a 1st June 2017 deadline for mixtures already in the supply chain by 1st June 2015

The Health and Safety (Safety Signs and Signals) Regulations 1996

The Health and Safety (Safety Signs and Signals) Regulations 1996 have also been updated and published following the passing of the CLP deadline. Generally the regulations haven’t changed much, with a few exceptions where reference to CHIP has been replaced with reference to CLP. You can download the new version of the Regulations but below is a summary of the main changes to be aware of;

Warning signs – General

Paragraph 48 (pg 14)

48 The ‘Harmful or irritant material’ warning sign (black cross on a yellow triangle warning sign) which previously appeared in the Regulations was removed by regulation 3(4)(c) of the CLP (Amendment) Regulations. Where employers would previously have used this they should now use the most relevant warning sign from the others available. Where the warning sign does not relate to the CLP Regulation new designs of pictograms may be developed as long as they are clear and meet these intrinsic features.

Warning signs – Chemical labelling and packaging

Paragraph 51-53 (pg 19)

51 These labels do not appear in Schedule 1 of the Regulations but in Annex V to the CLP Regulation. 52 There are no intrinsic features laid down for the labels under the CLP Regulation. You must use the most appropriate sign of those available and cannot create variations. 53 These labels do not form part of the Regulations but have an impact on signage used with hazardous substances and mixtures which have resulted in changes to those Regulations.

Using signs on containers and pipes

Paragraph 56-57 (pg 20)

The CLP (Amendment) Regulations amend the provisions relating to containers and pipes. Where these containers or pipes are not excepted and are used for, contain or are involved in the transporting of hazardous chemical substances and mixtures, they must be labelled in accordance with the CLP Regulation, using the relevant hazard pictogram from Annex V to the CLP Regulation. 57 However, the CLP (Amendment) Regulations also permit use of the hazard warning symbols specified in other systems so labels can be: (a) replaced by warning signs from Part II of Schedule 1 of the Regulations, provided they contain the same pictograms or symbols. If there is no equivalent in Part II, the relevant hazard pictogram from Annex V of the CLP Regulation must be used; (b) supplemented by additional information, eg about the risk or the hazardous chemical; (c) in the case of containers transported at the place of work, supplemented or replaced by EU applicable signs.

Confusion is unlikely to arise since similar pictograms are used in the different types of signs. What may differ are the shape and the colour of the signs.

Using signs to mark areas, rooms and enclosures

Paragraph 62 (pg 21)

Where stores are being used for hazardous chemicals or mixtures they should be indicated by the relevant warning sign taken from paragraph 3.2 of Part II of Schedule 1 of the Regulations (the yellow triangle black pictogram warning signs). If there is no equivalent warning sign in these provisions then the relevant hazard pictogram from Annex V to the CLP Regulation must be used. Stores containing a number of different substances may be indicated by the ‘general danger’ warning sign