21 January 2015
Do users of chemicals need to be worried about the new CLP regulation? Evans Vanodine sets out the facts
From 1st June 2015 all chemical products will be labelled under the new Globally Harmonised System of Classification and Labelling of Chemicals (GHS). It is implemented in the EU via the Classification, Labelling and Packaging Regulation (CLP), where previously chemical products were regulated in the UK under CHIP.
The main changes will be the introduction of red diamond shaped Hazard Pictograms to replace the orange square Hazard Symbols; ‘Indication of Danger’ words Toxic, Corrosive, Irritant etc will be replaced by two new ‘Signal Words’ - ‘DANGER’ and ‘WARNING’ and ‘Risk (R) Phrases’ are changing to ‘Hazard (H) Statements’ and the ‘Safety (S) Phrases’ are changing to ‘Precautionary (P) Statements’.
As before, a system of calculations and thresholds is used to classify products. However, some of the threshold levels under CLP are lower than under CHIP. For example under the CHIP system a product would need to contain more than 20% of an ingredient classified as R36 (Irritating to eyes) to trigger an ‘Irritant’ hazard symbol but under CLP this is reduced to 10% to trigger a hazard pictogram. This may result in many products being classified where previously they were not, maybe as many as 80%.
This reduction in threshold levels will particularly affect the Hazard H318 ‘Causes serious eye damage’ (which was R41 ‘Risk of serious damage to eyes’ under CHIP). This has changed significantly from a 10% threshold triggering an ‘Irritant’ symbol to a 3% threshold, triggering a GHS05 ‘Causes Damage’ pictogram. This symbol, which is very similar to the CHIP symbol for corrosive, will still be used on high caustic products, such as auto dishwash and oven cleaner, but will now also appear on products with a much lower active content which were not previously classified.
The ripple effect
The presence of a new Hazard Pictogram on a label does not signify a change in the formulation, since it is the same chemical composition, it is just a consequence of compliance with the new classification system. However, one of the main concerns regarding CLP for our industry is how the end user and Health & Safety Officers will react to seeing these Hazard Pictograms on products which they have used safely for many years.
- Will chemical manufacturers reduce the activity of their products so they are below the threshold levels, just to avoid classification?
- Will we see a shift from concentrate chemicals, which will now most definitely have to display Hazard Pictograms on the label, to diluted, ready to use products?
It is ironic that after spending many years researching, developing and promoting concentrate formulations to overcome packaging waste and reduce the unnecessary transport of water, the new Hazard Pictograms may result in users demanding non-classified, weaker products. GHS and CLP have been introduced to harmonise the labelling of chemicals but will this have a knock on effect for the environment and sustainability?
It is going to be very important that users of chemicals are fully aware of the changes and understand the regulation. It is the responsibility of cleaning chemical manufacturers to communicate with customers and issue detailed product support information as the changes occur. This information will need to be relayed to end users so they recognise the new Pictograms and associated risks so they can review COSHH Risk Assessments and PPE if required. Indeed through consultation with the British Association of Chemical Specialities, the HSE is now keen to promote user understanding of CLP labels and to see employer COSHH assessments and training addressing the product label as a whole without over-emphasis on the pictogram.
As an exporter to over 75 counties worldwide, we accept and agree that a global system of classifying and labelling chemicals is necessary, but obviously there are concerns. We believe that education and training are the key to a smooth transition. After 20 plus years of CHIP symbols it is important that users are re-educated to understand what the new Pictograms and Statements represent. Whilst some of the internal images are similar, strictly speaking there is no direct equivalent from the CHIP symbols to CLP. It is now more important than ever that users read the accompanying Hazard Statements rather than just relying on a glance at the image.