GHS CLP ATREAT. The new classification and labelling of hazardous chemicals. Providing a single source for your water treatment chemicals

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1 GHS CLP The new classification and labelling of hazardous chemicals ATREAT Providing a single source for your water treatment chemicals

2 Dear customer The current European system for classification and labelling of chemicals is being replaced by CLP. This is the Regulation (EC) No 1272/2008 on Classification, Labelling and Packaging of Substances and Mixtures. We would like to give you a compact overview of CLP: some background information, basic principles, a comparison between the new and old systems, and how it may impact on your company. We look forward to working with you towards a successful implementation of CLP. Should you have any further questions regarding this topic, please do not hesitate to contact us. Kind regards, Barbara Clearey Managing Director 1

3 GHS 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. Although similarities in the laws around the world exist, differences in the classification and labelling rules can lead to confusion. Due to the extensive global trade of chemicals it was internationally recognised that a harmonised classification and labelling system would be of advantage. In 2003 the United Nations initiated and organised the Globally Harmonized System of Classification and Labelling of Chemicals - GHS. 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.e. the communication of their potential hazards, by means of labels and Safety Data Sheets (SDS), towards workers and consumers. GHS is a binding international agreement and has to be implemented by countries in their local laws. In the EU the European Commission has prepared the implementation of GHS and developed the CLP Regulation. CLP CLP stands for Regulation (EC) No 1272/2008 on Classification, Labelling and Packaging of Substances and Mixtures. It entered into force on 20 January 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, so that people know about the effects before they handle them. Note that mixture now replaces the term preparation. 2

4 CLP - classification and labelling basics Three main types of hazards are defined: the physical hazard (e.g. Explosives, Self-reactive substances/ mixtures), the health hazard (e.g. Acute toxicity, Germ cell mutagenicity) the environmental hazard (e.g. Hazardous to the aquatic environment) The hazard classes are divided into hazard categories, specifying the hazard severity (e.g. Acute toxicity, categories 1,2) For some hazard classes there is a distinction depending on the route of exposure (oral, dermal, inhalation) or the nature of the effects (e.g. respiratory tract irritation, narcotic effects). CLP also introduces new symbols, the pictograms. They are characterised by a red frame and a white background. Old EU symbols have a black frame and an orange background. Also, CLP introduces two signal words Danger and Warning to alert the reader to a potential hazard. Danger indicates the more severe hazard categories and Warning the less severe hazard categories. Equivalent to the former R-phrases are the H-statements (e.g. H200, H201. These are the hazard statements which describe the nature of the hazards of a substance or mixture. And equivalent to the former S-phrases are the P-statements. These are the precautionary statements which describe recommended measures to minimise or prevent adverse effects. CLP also includes some aspects of previous EU legislation not included in GHS and these are the EUH-statements known as Supplemental Hazard Information. A comparison table between the former EU classification system and CLP is show on the next pages. This is a compact overview of the changes. It cannot be literally used to translate a former classification and labeling into a CLP one as there have been some changes to the hazard classification thresholds. 3

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7 Industry s roles and 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. Manufacturers of substances: Produces or extracts a substance in the natural state within the Community; Importers of substances or mixtures: Are responsible for the physical introduction into the customs territory of the Community; Downstream users, including formulators and re-importers: Other than the manufacturer or the importer, someone who uses a substance, either on its own or in a mixture, in the course of his industrial or professional activities; Distributors, including retailers: Store and place on the market a substance, on its own or in a mixture, for third parties. It should be noted that suppliers of substances or mixtures may have more than one role under CLP. Obligations under CLP As a downstream user or distributor you will have to classify your substances and mixtures according to CLP criteria. Labels and Safety Data Sheets will have to be changed. But as a customer of Aquatreat, all this will be completed for you. However, you will need to gain an understanding of CLP and its implications for your business, and your customers. You are recommended to develop a company inventory of your substances and mixtures; identify how you and your customers use the substance or mixtures. Much of this information may have already been collected in relation to REACH; review all data sheets to identify any changes in classification, hazard or precautionary statements as a result of CLP, and any impact this may have on storing, handling or using the products; assess the need for training of the appropriate technical and regulatory staff in your company; 6

8 CLP implementation transition period CLP will replace stepwise DSD and DPD, respectively the Dangerous Substances Directive (67/548/EEC) and the Dangerous Preparations Directive (1999/45/EC). These two directives shall be repealed with effect from 1 June From this date on CLP will be the only valid law for classification and labelling of substances and mixtures. There are certain timelines for the industry to classify and label their substances and mixtures in line with CLP. Substances From 1 December 2010 until 1 June 2015, substances shall be classified in accordance with both Directive 67/548/EEC and the CLP Regulation. They shall be labelled and packaged in accordance with the CLP Regulation. Mixtures (formerly called preparations in Dangerous Preparations Directive (1999/45/EC)) Until 1 June 2015, mixtures shall be classified, labelled and packaged in accordance with Directive 1999/45/EC. Mixtures classified, 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 Substances and mixtures may, before 1 December 2010 and 1 June 2015 respectively, be classified, labelled and packaged in accordance with the CLP Regulation. In this case the old classification and labelling must also be mentioned in the safety data sheet until 1 June

9 Impacts on your company Although CLP has been kept as close to the former EU classification as possible, there are some differences and in some cases chemicals will be classified more severely than now, or chemicals which were formerly not considered as hazardous will be classified as hazardous. This could have an impact on your storage and use of the product. The classification and labelling of chemicals regulation encounters other regulations e.g. in the sectors of environment, of occupational health and safety. It is recommended to plan CLP together with REACH, and the legislation on biocidal products (Directive 98/8/EC) as they are closely interlinked to CLP. For more information about CLP, Aquatreat recommends the websites: HSE Guidance on Globally harmonised systems: HSA GHS Information Sheet: ECHA Support guidance on REACH + CLP implementation support: The European Chemicals Agency (ECHA) Disclaimer: To the best of our knowledge, the information contained herein is accurate. However Aquatreat Chemical Products Limited does not accept liability whatsoever for accuracy or completeness of the information contained herein. It is for the users of this information to ensure it s accuracy. 8

10 Aquatreat Chemical Products Ltd Stanley House 9 Bunting Close Mitcham Surrey CR4 4ND Tel: +44 (0) Fax: +44 (0) ATREAT Providing a single source for your water treatment chemicals

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