GHS – CLPThe new classification and labelling of hazardous chemicals ............................6 Industry’s roles and obligations under CLP......5 Comparison table between the former EU classification system and CLP... We look forward to working with you towards a successful implementation of CLP.... Should you have any further questions regarding this topic................................................................... Labelling and Packaging of Substances and Mixtures................................ It entered into force on 20 January 2009................ CLP basic principles.....................4 CLP – what it is about... the schedule for the implementation.... the industry’s role and obligation......... With this brochure we would like to give you a short and compact overview of the main topics of CLP: some background information............... please do not hesitate to approach your BRENNTAG contact person......................... 8 Obligations under CLP........ This is the Regulation (EC) No 1272/2008 on Classification...... GHS – what it is about......................................................................................2 3 Table of contents Dear business partner................................................ 10 Impacts on your company....4 Some classification and labelling basics according to CLP.. Clare Waters ................ possible impacts on the application of other regulations and on your company...........................9 CLP implementation – transition period. 11 The current European system for classification and labelling of chemicals is getting replaced by CLP.................... Kind regards........ a comparison between the new and the former systems.. GHS has to be implemented by the regions and countries in their local laws. The aim of GHS is to enhance the protection of human health and the environment by harmonising worldwide: ❚ the criteria of classification of chemicals ❚ their labelling i. Acute toxicity. GHS is not an operative law.g. several countries and regions around the world have regulated their classification (identification of hazardous properties of a chemical) and labelling. H200. H201. They are characterised by a red frame and a white background. And equivalent to the former S-phrases are the P-statements. dermal. CLP – what it is about CLP stands for Regulation (EC) No 1272/2008 on Classification. towards workers and consumers. by means of labels and Safety Data Sheets (SDS). the same chemical could be labelled as ‘toxic’ in one country.e.g. but not in another. differences in the classification and labelling rules can lead to confusion.GHS. the health hazards and the environmental hazards. On the following page you can find a comparison table between the former EU classification system and CLP. whereas old EU symbols have a black frame and an orange background. In 2003 the United Nations initiated and organised the “Globally Harmonized System of Classification and Labelling of Chemicals” . it is a binding international agreement. Acute toxicity. These are the hazard statements which describe the nature of the hazards of a substance or mixture. Equivalent to the former R-phrases are the H-statements (e. Note that “mixture” means the same as the term “preparation” which has been used so far. Hazardous to the aquatic environment. ❚ the health hazard (e. In the EU the European Commission has prepared the implementation of GHS and developed the CLP Regulation. This table aims to give you a compact overview of the changes but it cannot be literally used to translate a former classification and labelling into a CLP one. specifying the hazard severity (e.2) For some hazard classes there is a distinction depending on the route of exposure (oral. Self-reactive substances/ mixtures).g.5 GHS – what it is about As chemicals can have potential adverse effects to people and the environment. Since 1967 the classification and labelling of hazardous substances has been regulated in the European Union (EU) and since 1988 the classification and labelling of hazardous preparations. Considering the extensive global trade of chemicals it was internationally recognised that a harmonised classification and labelling system would be of advantage. respiratory tract irritation. Some classification and labelling basics according to CLP Three main types of hazards have been defined: the physical hazards. Explosives. ‘Danger’ indicates the more severe hazard categories and ‘Warning’ the less severe hazard categories. categories 1. Germ cell mutagenicity) ❚ the environmental hazard (e. acute) The hazard classes are divided into hazard categories. Labelling and Packaging of Substances and Mixtures. It entered into force on 20 January 2009. the pictograms. CLP introduces two signal words ‘Danger’ and ‘Warning’ to alert the reader on a potential hazard. narcotic effects). inhalation) or the nature of the effects (e. These are the precautionary statements which describe recommended measures to minimise or prevent adverse effects.g.g. the communication of their potential hazards. It is the task of industry to establish what the hazards of substances and mixtures are before they are placed on the market (classification) and to inform people like workers and customers (labelling) about these hazards by means of labels and safety data sheets. CLP also introduces new symbols. so that people know about the effects before they handle them. For example.g. Although similarities in the laws around the world exist. Also. These are divided into hazard classes defined by the nature of: ❚ the physical hazard (e. . Dermal . R63 R68 R48 Germ cell mutagenicity.Inhalation WARNING H302 H312 H332 R34. category 2 Reproductive toxicity. categories 1. types C and D and types E and F Self heating substances/mixtures. category 1 H318 R38 R36 R43 Skin irritation. category 1 Flammable solids. R35 Skin corrosion. category 1 Flammable liquids.Liquefied gas .Narcotic effects H336 ENVIRONMENTAL HAZARDS R50 R50/53 R51/53 No symbol R52/53 No symbol R53 Hazardous to the aquatic environment. H272 H272 Gas under pressure . Category 1 Hazardous to the aquatic environment. Category 3/Category 4 H400 H410 WARNING R8 R8. 2 . Category 1 Hazardous to the aquatic environment. category 3 . category 1 Oxidising liquids. category 2 STOT***. category 2 Flammable solids.Dermal . category 1 Flammable aerosols. category 1 Explosives. types A and B Organic peroxides. types E and F H226 Acute toxicity. category 2 Eye irritation. 1B Reproductive toxicity. category 2 WARNING H341 H351 H361 H371 H373 R22 R21 R20 Acute toxicity. category 2 R28 R27 R26 TOXIC R11 (R11) (R11) Label Elements New** Acute toxicity . R9 R46 R45. repeated exposure.Oral . R3) Label Elements New** IRRITANT Explosives . category 1 H334 H304 R68 R40 R62. category 1 * Based on Annex I Regulation (EC) No 1272/2008 for all hazard categories with GHS pictograms ** Based on pictograms in Annex V Regulation (EC) No 1272/2008 *** Specific Target Organ Toxicity H280 H280 H281 H280 H290 DANGER DANGER H314 DANGER H241 H242 H242 H251 H252 H340 H350 H360 H370 H372 R37 WARNING H250 H250 H260 H261 H261 No symbol R67 No classification WARNING R8.4 Label Elements Old IRRITANT WARNING (R12) (R12) R12 No classification DANGER H204 Extremly Flammable H200 H201. 1B STOT***.Unstable explosives .3 Self-reactive substances/mixtures. H203 H240. H272 H272 H271. acute. categories 1A. division 1. type B Organic peroxides. category 2 STOT***. categories 1A.Dermal . 2 and category 3 Oxidising solids.Compressed gas . types A and B DANGEROUS FOR THE ENVIRONMENT Hazard Classes and Categories* DANGER Label Elements Old EXPLOSIVE Physical HAZARDS No pictogram H413 . single exposure. categories 1. H241 H240. 1B. category 1 Aspiration hazard. category 3 . single exposure. single exposure. category 1 H335 . category 2 Skin sensitisation.Explosives.Dissolved gas WARNING No classification Substances/mixtures corrosive to metals.Refrigerated liquefied gas . chronic. chronic. categories 1. category 1 Substances/mixtures which in contact with water emit flammable gases. category 3 R17 R17 (R15) (R15) (R15) OXIDISING Flammable Flammable aerosols.R61 R39 R48 H301 H311 H331 H411 – Organic peroxides. categories 1A.R49 R60. type B Self-reactive substances/mixtures. category 1 STOT***. category 2 R25 R24 R23 H300 H310 H330 No pictogram H412 – WARNING H223 No symbol (R10) No classification flashpoint 56-60°C VERY TOXIC WARNING H225 H228 H228 TOXIC Flammable liquids. 2 and category 3 Germ cell mutagenicity. category 2 Hazardous to the aquatic environment. H241 HigHLY Flammable (R2. repeated exposure. category 1 Pyrophoric solids.1 to 1.Respiratory tract irritation H315 H319 H317 H241 H242 H242 H270 H271. category 4 . 1C R41 Serious eye damage. types C and D Organic peroxides. division 1. chronic. R9 Oxidising gases.Inhalation – R7 R7 WARNING Self-reactive substances/mixtures. categories 1A. 1B Carcinogenicity.Oral . 2 and category 3 Extremly Flammable Flammable liquids.Inhalation HARMFUL DANGER H220 H222 H224 Hazard Classes and Categories* CORROSIVE Flammable gases. H202. categories 1.6 7 Comparison table between the former EU classification system and CLP HEALTH HAZARDS R42 R65 Respiratory sensitisation. category 2 Carcinogenicity. category 1 STOT***. category 1 and category 2 DANGER WARNING HigHLY Flammable R12 R12 OXIDISING Pyrophoric liquids.Oral . who uses a substance. who their suppliers and their customers are and how they use the substance or mixtures. It is therefore most important that you identify your role under CLP. You can check these details under: http://guidance. DPD2) or transport legislation need to be changed due to transition to CLP. ❚ update the software for the handling of Safety Data Sheets and new labels ❚ evaluate if your packaging that you apply to DSD1). CLP distinguishes among others between: As a manufacturer. ❚ Manufacturers of substances: A natural or legal person established within the Community who produces or extracts a substance in the natural state within the Community. Much of this information may have already been collected in relation to REACH. ❚ Distributors. other than the manufacturer or the importer. ❚ Downstream users. ❚ assess the need for training of the appropriate technical and regulatory staff in your company. ❚ check if you have sufficient appropriate technical and regulatory staff or if you need additional resources or external expertise. in the course of his industrial or professional activities. You will have to change their labels and Safety Data Sheets. including retailers: A natural or legal person established within the Community who only stores and places on the market a substance. In some cases you might need to change their packaging as well. either on its own or in a mixture. as suppliers of substances or mixtures you are recommended to ❚ develop a company inventory of your substances and mixtures (including those substances contained in mixtures) and substances contained in articles. 1) Dangerous Substances Directive (67/548/EEC) 2) Dangerous Preparations Directive (1999/45/EC) . It should be noted that suppliers of substances or mixtures may have more than one role under CLP. for third parties.9 Industry’s roles and obligations under CLP Obligations under CLP Roles under CLP The obligations placed on a supplier of substances or mixtures under CLP will mostly depend upon their role towards a substance or mixture in the supply chain.europa. To gain an understanding of CLP and its implications for business.eu/docs/guidance_document/ clp_introductory_en. including formulators and re-importers: A natural or legal person established within the Community. on its own or in a mixture.echa. Your specific obligations under CLP depend upon your role in the supply chain.pdf#page=10 ❚ Importers of substances or mixtures: A natural or legal person established within the Community who is responsible for the physical introduction into the customs territory of the Community. importer or downstream user you will have to classify your substances and mixtures according to the CLP criteria. ❚ Mixtures (former called ‘preparations’ in Dangerous Preparations Directive (1999/45/EC)) Until 1 June 2015. Mixtures classified.europa. amending and repealing Directives 67/548/EEC and 1999/45/EC.hsa. before 1 December 2010 and 1 June 2015 respectively. there are some differences and in some cases chemicals will be classified more severely than now.11 CLP implementation – transition period Impacts on your company CLP will replace stepwise DSD and DPD. labelling and packaging of substances and mixtures. From this date on CLP will be the only valid law for classification and labelling of substances and mixtures. of occupational health and safety.g. labelled and packaged in accordance with the CLP Regulation. labelled and packaged in accordance with Directive 1999/45/EC.uk/ghs/eureg. For further information on CLP impacts you can contact the environmental department of your chamber of industry and commerce or your trade associations and of course your BRENNTAG contact person. From 1 December 2010 until 1 June 2015. labelled and packaged in accordance with Directive 67/548/EEC. or chemicals which were formerly not considered as hazardous will be classified as hazardous. substances shall be classified in accordance with both Directive 67/548/EEC and the CLP Regulation.ie/eng/Topics/Chemicals/CLP/ Sources: REGULATION (EC) No 1272/2008 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 16 December 2008 on classification.asp .europa.europa.eu/help/nationalhelp_en. Although CLP has been kept as close to the former EU classification as possible. as they are closely interlinked to CLP. and amending Regulation (EC) No 1907/2006 ECHA http://echa. if applicable. to the legislation on biocidal products (Directive 98/8/EC) and to the legislation on plant protection products (Council Directive 91/414/EEC). Substances and mixtures may.asp ❚ The European Commission Enterprise and Industry Chemicals http://ec. substances shall be classified.europa. For more information about CLP. This could have a major impact on your warehouse organisation.htm ❚ HSE Guidance on Globally harmonised systems: http://www. ❚ Substances Until 1 December 2010. labelled and packaged in accordance with Directive 67/548/EEC and already placed on the market before 1 December 2010. They shall be labelled and packaged in accordance with the CLP Regulation. labelled and packaged in accordance with Directive 1999/45/EC and already placed on the market before 1 June 2015 are not required to be relabelled and repackaged in accordance with the CLP Regulation until 1 June 2017. are not required to be relabelled and repackaged in accordance with the CLP Regulation until 1 December 2012. These two directives shall be repealed with effect from 1 June 2015. mixtures shall be classified.hse. in the sectors of environment. It is recommended to plan CLP processes together with processes related to REACH. The classification and labelling of chemicals regulation encounters other regulations e.htm ❚ HSA REACH and CLP Helpdesks (Ireland): http://www.eu/clp/clp_regulation_en.gov. respectively the Dangerous Substances Directive (67/548/EEC) and the Dangerous Preparations Directive (1999/45/EC). In this case the old classification and labelling must also be mentioned in the safety data sheet until 1 June 2015. There are certain timelines for the industry to classify and label their substances and mixtures in line with CLP. be classified.eu/enterprise/sectors/chemicals/classification/ index_en.eu/ ❚ The ECHA proposes a list of national helpdesks: http://echa. BRENNTAG recommends the websites: ❚ The European Chemicals Agency (ECHA) http://echa. Substances classified. at the end of 2010.Yeadon.❚ Brenntag UK & Ireland Albion House Rawdon Park Green Lane . Leeds LS19 7XX Phone: +44 (0)1133/879200 Fax : +44 (0)1133/879280 ❚ Brenntag Colours Ltd* High Level Way Halifax. HX1 4PN West Yorkshire England Phone: +44 (0)1422/358431 Fax : +44 (0)1422/330867 +44 (0)1422/381422 * please note that we are currently Albion Colours at the above address but will be changing to Brenntag Colours Ltd. .
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