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September 16, 2015

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CLP is here, now – but are you in compliance?

By Mike Taylor, Santia Consulting

After a lengthy transition period, the CLP Regulation became applicable to mixtures (previously known as preparations) on 1 June 2015.

The European regulations which concern classification, labelling and packaging (or to give them their full name – Regulation (EC) No 1272/2008 of the European Parliament and of the Council of 16 December 2008 on classification, labelling and packaging of substances and mixtures, amending and repealing Directives 67/548/EEC and 1999/45/EC, and amending Regulation (EC) No 1907/2006) came into being on 20 January 2009.

Since 1 December 2010 the law has applied to substances that are placed on the market. However, a derogation still exists if mixtures are classified, labelled and packaged in line with the ‘old’ rules (CHIP) – if they have already been “placed on the market” before 1 June 2015, the mixture does not have to be relabelled and repackaged in accordance with the CLP rules by the supplier until 1 June 2017.

So what are the key changes brought about by CLP?

Overall, the aim of the CLP Regulation is very similar to CHIP – substances and mixtures that are placed on the market must first be classified, labelled and packaged appropriately. One key difference however, is that CLP implements GHS (Globally Harmonised System of classification and labelling of chemicals), so the same classifications and labelling will be used everywhere.

As far as labelling is concerned, the most noticeable change is in relation to the symbols that are used. To accompany the new images, hazard and precautionary statements were introduced which replaced the old risk and safety phrases. CLP also introduced two new “signal words” – if the chemical poses a more severe hazard, the label includes the signal word ‘Danger’; in case of less severe hazards, the signal word is ‘Warning’.

Because the classification criteria methods are different for some types of hazard, another noticeable change is that some chemical products may be classified more or less severely than they were before (therefore, people may need to check whether the classification has changed for the chemicals that they use).

Employers need to ensure that they, and their employees recognise and understand the new label information. Where the classification of substances or mixture has changed, it may also be necessary to review and update chemical risk assessments (CoSHH Assessments) and procedures/safe systems of work.

Businesses also need to make sure the safety data sheets are updated in line with CLP – not only from the manufacturer’s perspective (including the supply of mixtures, inter-company shipments and waste), but also on the user’s side – (i.e. information from their suppliers).

Mike Taylor Santia]Mike Taylor is technical director at Santia Consulting Ltd. He will be presenting SHP’s bi-annual legislation update webinar in October 2015.

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