About The New Chemical Hazard Classification System For Product Labelling

Transcription

1 About The New Chemical Hazard Classification System For Product Labelling Classification, Labelling & Packaging (CLP) Regulations Effective 1 st June 2015 RP Adam Ltd: technicalsolutions@rpadam.co.uk Issue 1: 31 st March 2015

2 Keeping You Up To Speed With Changes To Labelling This document is the first issue in a series which will be distributed regularly to keep RP Adam staff, distributors and customers up to speed with changes to product labelling. Over the course of the next two months we will be working tirelessly to ensure ALL RP Adam Ltd product labels are revised to comply with the new CLP Regulations for the 1 st June 2015 deadline. If there are any questions at any stage please refer them to our address: technicalsolutions@rpadam.co.uk As part of this process we intend for the new product labels to contain more product information, application advice and detailed health & safety information than ever before, so that the chemical container almost becomes a Product Guidance Sheet in itself. We hope you find the enclosed useful.

3 Background & Introduction Most of the chemicals you might use are not dangerous if you use them properly but some chemicals need more careful handling than others. Labels can help you identify the more hazardous chemicals, tell you what the hazards are and how to avoid them. Where the supplier concludes that no hazardous properties have been identified, a chemical is not classified as hazardous and there is often nothing more to do. But where the supplier does conclude that a chemical could cause harm, they are expected to provide information about this on the label. A hazard label is made up of specific symbols and warning statements that are set out in law and chemical suppliers must use them where hazardous properties have been identified. The following presentation from RP Adam outlines the key changes that come into force in June 2015 with the new CLP Regulations: Chemical Hazard Information and Packaging.

4 The Real Impact: No Cause for Alarm It is estimated that 80-90% of professional cleaning products currently available will be classified as hazardous in some shape or form using the new CLP calculation method. So what options are available to the manufacturer to reduce hazard classifications? Make the formulations weaker so that the ingredient concentrations fall below the concentration thresholds set by the CLP Regulations. This is likely to reduce the product performance and, arguably, supplying less concentrated products is not environmentally responsible because we will use more and create more waste. Alternatively, communicate the fact that the new hazard symbols should not cause alarm for the professional user, but in fact serve as a useful reminder of proper safety practises and the potential dangers if chemicals in general are not handled and stored properly. Use controlled dispensing systems to reduce the risk of contact with concentrated chemicals, because most if not all ready-to-use solutions are classified as non-hazardous.

5 Moving to CLP Hazard System After June 2015, all hazardous products on the market will have new CLP warning symbols or pictograms (red diamonds) and warning messages on the label and safety data sheet. The new CLP hazard classification system means that, in some cases, hazard pictograms will appear on labels of existing chemical products where previously there was no hazard symbol. This does not mean that the chemical itself is any more dangerous than it was before, it is just a result of the way in which the new classification system is calculated. Hazard classification is an exercise that decides what potential dangers are presented for each chemical, what hazard symbols should appear on the label and the safety advice that must be provided. CLP uses different methods and criteria to classify hazards and in some cases we will see cleaning products, which previously had no orange box hazard symbols under CHIP, having a red diamond hazard pictogram according to CLP.

6 The NEW CLP Hazard Pictograms This is a not an exhaustive list but these symbols apply to RP Adam Ltd chemicals

7 Key Differences New CLP System Classification criteria and methods are different for some types of hazard, so some chemical products may be classified more or less severely. New red diamond hazard pictograms will replace orange box hazard symbols on labels. Although many of the icons within the pictogram are similar to those used in CHIP, CLP introduces some new icons. The CHIP warnings, which appear under the orange hazard symbols, such as Corrosive and Irritant are no longer used with the more generic DANGER or WARNING appearing on a new CLP label. New wording will appear on product labels with H (Hazard) statements and P (Precautionary) statements replacing Risk and Safety phrases. Expect to see more warning statements than before.

8 The NEW CLP Hazard Pictograms FLAMMABLE ENVIRONMENT CORROSIVE HARMFUL/IRRITANT DANGER WARNING DANGER DANGER WARNING DANGER

9 The NEW CLP Hazard Pictograms The CLP Regulation introduces two new signal words: DANGER and WARNING. If the chemical has a more severe hazard, the label includes the signal word Danger and in case of less severe hazards, the signal word is Warning. DANGER: Substances or mixtures which cause severe skin burns and/or eye damage and may be corrosive to metals. WARNING: Substances or mixtures that may cause skin and eye irritation or adverse health effects. WARNING: Substances or mixtures that are toxic aquatic organisms and can cause long term damage to environment.

10 The NEW CLP Hazard Pictograms DANGER/WARNING: Substances or mixtures that may catch fire if a source of ignition is present. WARNING: Substances or mixtures that may cause allergy, asthma or breathing difficulties when inhaled or may be fatal or harmful if swallowed or if it enters airways. DANGER/WARNING : Substances or mixtures which cause or intensify fire and explosion.

11 Treat Chemicals With More Respect It is always important to treat all professional cleaning products with respect. Higher surfactant (cleaning) and biocidal active (germ killing) concentrations in these types of professional formulations are required to get the job done in the real world. The challenge we face is that the hazard associated with the product can be exaggerated by the pictogram. In some cases a product with the DANGER pictogram suggests that the liquid might burn skin when the hazard classification indicates that it does not. Remember that it is the RISK of harm that is the important issue here rather than just the HAZARD symbol on the product label and the message needs to be communicated clearly. When you see any hazard symbol, read what is actually the written on the label, read the Safety Data Sheet and take appropriate precautions.

12 New Hazard (H) Statements A hazard (H) statement is a phrase that describes the nature of the hazard in the substance or mixture. A hazard statement will be determined by the application of the classification criteria. Examples of H statements include: Causes serious eye damage. Causes severe burns to skin. Toxic if swallowed. Toxic to the aquatic life with long lasting effects. May cause allergy or asthma symptoms or breathing difficulties if inhaled. It replaces the risk or R-phrase used in CHIP. Found on the NEW product label and the NEW CLP compliant Safety Data Sheet

13 Precautionary (P) Statements A precautionary (P) statement is a phrase that describes recommended measure(s) to minimise or prevent adverse effects resulting from exposure to a hazardous substance or mixture due to its use or disposal. Examples of P statements include: Wear eye protection. Do not eat, drink or smoke when using this product. Avoid release to the environment. In case of inadequate ventilation wear respiratory protection. Suppliers determine the appropriate precautionary statements (usually no more than six) that are most relevant to the mandatory hazard statements and how the product is normally used. It replaces the safety or S-phrase used in CHIP. Found on the NEW product label and the NEW CLP compliant Safety Data Sheet

14 The Most Significant Changes A new symbol will be introduced which identifies chemicals that can cause very serious long term health effects. The symbol might be used where exposure to a chemical can cause damage to specific organs or parts of the body. WARNING For example sensitisers that can cause allergic reactions or substances that can cause lung damage by suffocation after swallowing.

15 The Most Significant Changes The most significant change to the new CLP rules is the use of this pictogram: DANGER. The use of a pictogram with an icon similar to the one used for CORROSIVE symbol under CHIP may ring a few alarm bells with end users of products that they have been using for years. DANGER Almost all surfactants used in cleaning products are classified as risk of serious damage to eyes under the old CHIP system. Previously, a chemical mixture would need to contain 10%+ to trigger this classification and an orange IRRITANT symbol would be used on the label. Now, under CLP, only 3% surfactant is required to trigger the need for the pictogram with the corrosive icon and a mere 1% is enough to add the exclamation mark pictogram to the label.

16 The Most Significant Changes Note: This symbol does NOT always mean Corrosive The same corrosive Danger symbol could appear on product labels, where there is no evidence of corrosive effects to skin as CLP uses the same symbol to show that a product has: DANGER The potential to attack metal surfaces. OR Causes severe damage to eyes.

17 The Most Significant Changes DANGER Mixture Description CHIP CLP Product containing 9.9% of a surfactant ingredient considered to be a severe eye irritant Product containing 3.0% of a surfactant ingredient considered to be a severe eye irritant Product containing 1.0% of a surfactant ingredient considered to be a severe eye irritant No symbol No symbol More ingredients are classified as hazardous to the environment. Expect almost all concentrated disinfectant products to be classified as hazardous to the environment. These include washroom and kitchen sanitisers and terminal disinfectants. Remember, if diluted correctly however, ready to use solutions are not classified as hazardous. WARNING

18 How are NEW Hazards Formulated Mathematical calculations are used to predict hazard classifications as this avoids any need for the unethical testing of chemicals on animals. With the new CLP system, the thresholds of ingredient concentration that trigger a hazard classification are generally lower under CHIP and this has significant implications for product labelling. The chemical composition of a cleaning product may remain unchanged but the hazard classification and labelling may change quite radically. The calculation rules used for CLP classification will result in many existing professional cleaning products having a hazard pictogram, where previously the product would not have been classified as hazardous and no orange symbol would be needed.

19 CHIP v CLP: Cup of Tea Analogy You could think about CLP and CHIP in terms of sugary tea: Under CHIP adding 10 lumps was dangerous, adding 3 lumps might need a health warning. But under CLP, 3 lumps is now considered Dangerous to health and 1 lump now needs a warning! The cup of tea is still the same as before, but the safe level for adding sugar is now lower. Same tea, different rules! Or Or

20 Examples of CLP New Labels Copy

21 Key Action Points with New System Look out for new labels and supporting product information and safety data sheets. Train employees to recognise and understand the new label information. Check that the way you use chemical cleaning products is in accordance with advice from the supplier. Follow the advice provided on the new labels and in safety data sheets. Check whether product hazard classifications have changed. Evaluate the risks to workers and update your workplace COSHH risk assessments if necessary. If you are an employer, communicate these changes to your employees and if you have any questions about the new labels or safety data sheets, speak to RP Adam Ltd.

22 Implications of NEW CLP System The administrative burden is considerable and these changes to chemical hazard classifications causes several issues for the professional cleaning industry manufacturer, distributor and business consumer. There will be a dramatic increase in the number of chemical products labelled with the corrosive pictogram. This is not because they have become more dangerous but as a result of a new system of classification. There will be an increase in the requirement for and provision of PPE (Personal Protective Equipment) for staff using professional cleaning products in response to the new symbols. Many businesses today do not provide adequate quantities of PPE for staff; this now becomes a top priority.

23 Are You Using Concentrates? Professional cleaning products are used in huge quantities every day across all types of businesses. Manufacturers have to bring consumables costs down and be mindful of the environmental impacts these types of products present. Manufacturers therefore need to invest in developing chemical concentrates, essentially getting the most out of a bottle, rather than putting less in. As long as the hazardous concentrate is packaged robustly and dispensed safely, the risk to the user is minimised. An example is a super concentrated kitchen sanitiser which may be classified in concentrate form as follows: But when diluted via a chemical mixing station the ready-to-use cleaning solution carries no hazard symbol as it is safely pre-mixed with water at dilutions of up to 100:1.

24 Change to Safety Data Sheets (SDS) Safety Data Sheets (SDS) are governed by a separate set of regulations called REACH, but where CLP brings about changes to hazard classification, new SDS will be issued containing the new H and P statements and hazard pictograms. The regulations for transport are not changed by CLP and the same is true for storage however, as the hazard symbols are similar to transport diamonds, it may be possible to avoid an additional transport diamond under some circumstances. After June 2015, new CLP compliant SDS will be available to download from our website although there may still be CHIP classified products available on the market from other suppliers.

25 Summary CLP is a European Regulation that affects all chemical products made after June CLP classification is more stringent than before, so expect all products that currently have an orange hazard symbol to have one or more hazard diamonds. Products previously with no hazard warnings MAY now have a CLP hazard classification. For the next 2 years there will still be products on the market that have been classified using the old CHIP system, so two identical chemical products sitting side by side can have different labels (Confusion?) The danger symbol and safety information may have changed, but this does not mean the product in the bottle is different. What should you do when you see products with new CLP labels? Same as before READ THE LABEL and for more information refer to the Safety Data Sheet.

26 Your Information Resource Centres Company Website: The Company Blog: CLP Web Page: CLP e-book: