ATREAT

GHS – CLPThe new classification and labellingof hazardous chemicals

Providing a single source for your water treatment chemicals

Dear customer

The current European system for classification and labellingof chemicals is being replaced by CLP. This is theRegulation (EC) No 1272/2008 on Classification, Labellingand Packaging of Substances and Mixtures.

We would like to give you a compact overview of CLP:some background information, basic principles, acomparison between the new and old systems, and howit may impact on your company.

We look forward to working with you towards a successfulimplementation of CLP.

Should you have any further questions regarding thistopic, please do not hesitate to contact us.

Kind regards,

Barbara CleareyManaging Director

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GHS

Since 1967 the classification and labelling of hazardoussubstances has been regulated in the European Union (EU) andsince 1988 the classification and labelling of hazardouspreparations. Although similarities in the laws around the worldexist, differences in the classification and labelling rules can leadto confusion.

Due to the extensive global trade of chemicals it wasinternationally recognised that a harmonised classification andlabelling system would be of advantage. In 2003 the UnitedNations initiated and organised the “Globally Harmonized Systemof Classification and Labelling of Chemicals” - GHS.

The aim of GHS is to enhance the protection of human healthand 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), towardsworkers and consumers.

GHS is a binding international agreement and has to beimplemented by countries in their local laws. In the EU theEuropean Commission has prepared the implementation of GHSand developed the CLP Regulation.

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CLP

CLP stands for Regulation (EC) No 1272/2008 on Classification,Labelling and Packaging of Substances and Mixtures. It enteredinto force on 20 January 2009. It is the task of industry toestablish what the hazards of substances and mixtures arebefore they are placed on the market (classification) and toinform people like workers and customers (labelling) about thesehazards by means of labels and safety data sheets, so thatpeople know about the effects before they handle them.

Note that “mixture” now replaces the term “preparation”.

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 aquaticenvironment)

The hazard classes are divided into hazard categories, specifyingthe hazard severity (e.g. Acute toxicity, categories 1,2)

For some hazard classes there is a distinction depending on theroute of exposure (oral, dermal, inhalation) or the nature of theeffects (e.g. respiratory tract irritation, narcotic effects).

CLP also introduces new symbols, the pictograms. They arecharacterised by a red frame and a white background. Old EUsymbols have a black frame and an orange background. Also,CLP introduces two signal words ‘Danger’ and ‘Warning’ toalert the reader to a potential hazard. ‘Danger’ indicates themore severe hazard categories and ‘Warning’ the less severehazard categories.

Equivalent to the former R-phrases are the H-statements (e.g.H200, H201. These are the hazard statements which describethe 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 describerecommended measures to minimise or prevent adverse effects.

CLP also includes some aspects of previous EU legislation notincluded in GHS and these are the EUH-statements known asSupplemental Hazard Information.

A comparison table between the former EU classification systemand CLP is show on the next pages. This is a compact overviewof the changes. It cannot be literally used to translate a formerclassification and labeling into a CLP one as there have beensome changes to the hazard classification thresholds.

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Industry’s roles and obligations under CLP

Roles under CLPThe obligations placed on a supplier of substances or mixturesunder CLP will mostly depend upon their role towards asubstance or mixture in the supply chain.

• Manufacturers of substances: Produces or extractsa substance in the natural state within the Community;

• Importers of substances or mixtures: Are responsiblefor the physical introduction into the customs territory ofthe Community;

• Downstream users, including formulators and re-importers:Other than the manufacturer or the importer, someone who usesa substance, either on its own or in a mixture, in the courseof his industrial or professional activities;

• Distributors, including retailers: Store and placeon the market a substance, on its own or in a mixture,for third parties.

It should be noted that suppliers of substances or mixtures mayhave more than one role under CLP.

Obligations under CLP

As a downstream user or distributor you will have to classifyyour substances and mixtures according to CLP criteria. Labelsand Safety Data Sheets will have to be changed. But as acustomer of Aquatreat, all this will be completed for you.

However, you will need to gain an understanding of CLP and itsimplications for your business, and your customers. You arerecommended to

• develop a company inventory of your substances and mixtures;

• identify how you and your customers use the substance ormixtures. Much of this information may have already beencollected in relation to REACH;

•review all data sheets to identify any changes in classification,hazard or precautionary statements as a result of CLP, and anyimpact this may have on storing, handling or using the products;

• assess the need for training of the appropriate technicaland regulatory staff in your company;

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CLP implementation – transition period

CLP will replace stepwise DSD and DPD, respectively theDangerous Substances Directive (67/548/EEC) and the DangerousPreparations Directive (1999/45/EC). These two directives shallbe repealed with effect from 1 June 2015. From this date onCLP will be the only valid law for classification and labelling ofsubstances and mixtures.

There are certain timelines for the industry to classify and labeltheir substances and mixtures in line with CLP.

• SubstancesFrom 1 December 2010 until 1 June 2015, substances shall beclassified in accordance with both Directive 67/548/EEC andthe CLP Regulation. They shall be labelled and packaged inaccordance with the CLP Regulation.

• Mixtures (formerly called ‘preparations’ in DangerousPreparations Directive (1999/45/EC))Until 1 June 2015, mixtures shall be classified, labelled andpackaged in accordance with Directive 1999/45/EC.

Mixtures classified, labelled and packaged in accordance withDirective 1999/45/EC and already placed on the market before1 June 2015 are not required to be relabelled and repackagedin accordance with the CLP Regulation until 1 June 2017.

Substances and mixtures may, before 1 December 2010 and 1June 2015 respectively, be classified, labelled and packaged inaccordance with the CLP Regulation. In this case the oldclassification and labelling must also be mentioned in the safetydata sheet until 1 June 2015.

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Impacts on your company

Although CLP has been kept as close to the former EUclassification as possible, there are some differences and insome cases chemicals will be classified more severely thannow, or chemicals which were formerly not considered ashazardous will be classified as hazardous. This could have animpact on your storage and use of the product.

The classification and labelling of chemicals regulation encountersother regulations e.g. in the sectors of environment, ofoccupational health and safety. It is recommended to plan CLPtogether 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 thewebsites:

• HSE Guidance on Globally harmonised systems:http://www.hse.gov.uk/ghs/eureg.htm

• HSA GHS Information Sheet:http://www.hse.gov.uk/ghs/information-sheet.pdf

• ECHA Support guidance on REACH + CLP implementationsupport: http://echa.europa.eu/support

• The European Chemicals Agency (ECHA)http://echa.europa.eu/

Disclaimer: To the best of our knowledge, the information contained herein isaccurate. However Aquatreat Chemical Products Limited does not accept liabilitywhatsoever for accuracy or completeness of the information contained herein. Itis for the users of this information to ensure it’s accuracy.

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Aquatreat Chemical Products LtdStanley House9 Bunting CloseMitchamSurreyCR4 4ND

Tel: +44 (0)20 8401 8391Fax: +44 (0)20 8401 8392

support@aquatreat.uk.com

www.aquatreat.uk.com

Providing a single source for your water treatment chemicals

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