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36 | l&l news analysis All change for chemical labeling New UN regulations will challenge converters to ensure that chemical labels are compliant and contain readable information. Simon Robinson, of chemical industry software specialist Safeware Quasar, reports The chemicals industry is currently going through one of the most dramatic periods of change in its history, with a range of new regulatory regimes presenting unique challenges for business in this sector. All parts of the supply chain, including suppliers and users of chemicals, need to prepare for the transition from the current CHIP system to the CLP regulations, which will implement the United Nations Globally Harmonised System (GHS) for classifying and labeling chemicals. This article will look at the background to the legislation, some of the similarities and differences with current regulations, transition timescales for the new regulations, and how the legislation may develop in the future. The United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals, or GHS, is an internationally agreed-upon system set to replace the various different classification and labeling standards used in different countries. It is contained within the UN GHS ‘Purple Book’, which is not a formal treaty but a non-legally binding international agreement that provides countries with a regulatory framework to develop or modify existing programs. Countries (or trading blocks) must create local or national legislation to implement the GHS. Within Europe, for example, Regulation EC 1272/2008 Classification, Labeling and Packaging of Hazardous Substances and Mixtures (CLP) has been developed. The proposed new regulation will replace: • the Dangerous Substances Directive (67/548/EEC) and • the Dangerous Preparations Directive (1999/45/EC). These directives have been implemented in the UK, for example, as the Chemicals Hazard Information and Packaging for supply Regulations (CHIP). These CHIP regulations will be fully repealed in 2015 and replaced with a new set of regulations, which are likely to be called CHIP 4. The GHS will use consistent criteria for classification and labeling on a global level. Development began at the United Nations Rio Conference in 1992, when the International Labour Organization (ILO), the Organization for Economic Co-operation and Development (OECD), and various governments and stakeholders came together at the United Nations. The targets of GHS are to enhance protection to human health and the environment by: • Providing an internationally comprehensible system for hazard communication • Providing a recognized framework for those emerging nations without an existing system • Facilitating international trade in chemicals whose hazards have been properly assessed and identified on an international basis • Reducing the need for animal testing and evaluation of chemicals. Labels&Labeling GHS, a new system based on the various regulatory frameworks already in existence, harmonizes the very successful UN system for Transportation of Dangerous Goods (Orange Book). It is accepted that there will be teething problems and anomalies, which will be ironed out with refinements and the introduction of more comprehensive guidance documentation. Preparing for the new CLP regulations will require significant retraining at all levels of the supply chain, from the industrial regulatory experts and chemical operators down to the consumers. The visual impact of CLP will be very apparent. Orange/black ‘hazard symbols’ will be replaced by red/black diamonds called ‘pictograms’. Risk and Safety phrases (R and S phrases) are now replaced by Hazard and Precautionary statements. Hazard statements are separated into H200s Physical hazards; H300s, Health hazards; and H400s, Environmental hazards. There is a more comprehensive coverage of hazardous properties and many of the phrases, although having a similar meaning, are worded differently. For example: ‘R28 Toxic if swallowed’ is replaced by ‘H300 Fatal if swallowed’. ‘R42 May cause sensitization by inhalation.’ Is replaced by ‘H334 May cause allergy or asthma symptoms or breathing difficulties if inhaled.’ Precautionary statements are separated into P100s for General; P200s for Prevention; P300s for Response; P400s for Storage; and P500s for Disposal. The precautionary phrases are far more detailed and are allocated according to the relevant hazards. A global signal word of either ‘Danger’ or ‘Warning’ is assigned to the high hazard categories. Apart from the obvious change in the actual symbols used, products with lower hazard will attract a pictogram. There are likely to be more hazard statements and a ‘signal’ word. Precautionary statements will increase dramatically, as there is still currently little guidance on the order of precedence. Companies having to redesign labels will clearly have a serious challenge to ensure that the labels are compliant and contain all the information in a readable format. Important dates for the implementation of CLP • The CLP regulation entered into force on 1 January 2009. • The EC directives (67/548/EC and 1999/45/EC) will be repealed with effect from 1 June 2015. • The target date for Classification, Labeling and Packaging of Substances is 1 December 2010. Until 1 June 2015, the classification of substances according to both the EC directives and the CLP regulation needs to be shown in the safety data sheet (SDS), when the product is classified and labeled according to the CLP regulation. This
LabeLs&LabeLing |37 tHe visuaL iMpact of cLp wiLL be very apparent. orange/bLacK ‘Hazard syMboLs’ wiLL be repLaced by red/bLacK diaMonds caLLed ‘pictograMs’ gHS-01 Explosives self-reactive substances and mixtures, types A, b Organic peroxides, types A, b means that the classification of substances according to the EC directive will be available throughout the whole transition period until 1 December 2015. The target date for classification, labeling and packaging of mixtures is 1 June 2015. For mixtures, there is a provision to use the current Eu Directive 1999/45/EC until 30 May 2015. using the CLP regulation before this date will require the current Eu Classification to be used on the SDS. Substances and mixtures already placed on the market, for example in a warehouse, on the shelf, need not be relabeled or repackaged according to the CLP regulation until two years later – i.e. for substances on 1 December 2012, for mixtures on 1 June 2017. deveLopMents united nations Globally Harmonised System of Classification and Labeling of Chemicals (GHS) is contained within the ‘Purple Book’. This was first published in 2003 and is revised every two years. The un work programs continue to be developed and to refine the un GHS in biennial work programs. the un gHs subcommittee last met in december 2008 in geneva, where the following items were amongst those topics for discussion: • Aerosol flammability • Combined hazard and precautionary statements • Labeling of small packages • Development of criteria for the classification and labeling of substances hazardous to the terrestrial environment • Differential between strong and weak sensitizers. The un website at http://www.unece.org is regularly updated with the latest GHS developments. gHS-02 gHS-03 gHS-04 NEW gHS-05 Flammable gases, aerosols, liquids or solids self-reactive substances and mixtures Pyrophoric liquids and solids self-heating substances and mixtures substances and mixtures, which in contact with water emit flammable gases Organic peroxides Oxidizing gases, liquids and solids compressed gases liquefied gases Refrigerated liquefied gases Dissolved gases corrosive to metals skin corrosion severe eye damage gHS-06 Acute toxicity (cat 1 – 3) gHS-07 NEW gHS-09 Acute toxicity (cat 4) skin and eye irritation skin sensitisation specific Target Organ Toxicity Respiratory tract irritation Narcotic effects hazardous to the aquatic environment No current symbol may 2009 | L&L
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