CLP

The Globally Harmonised System (GHS) and Classification, Labelling and Packaging (CLP) Legislation

What is CLP?
European regulation (EC) No 1272/2008 implements the Globally Harmonised System (GHS) in Europe as the Classification, Labelling and Packaging (CLP) regulation for substances and mixtures. This regulation will replace the Dangerous Substances Directive (67/548EEC) as well as the Dangerous Preparations Directive (1999/45/EC) and amends Regulation (EC) No 1907/2006 – Registration, Evaluation, Authorisation of Chemicals (REACH). It stipulates that from December 2010 onwards substances will need to be classified and labelled in accordance with the new rules, and from June 2015, mixtures will also be included.

Who is affected?
The new Classification, Labelling and Packaging (CLP) Regulation will affect:
-       All REACH registrants, i.e. manufacturers or importers of substances or mixtures (preparations)
-       Downstream users (formulators of mixtures, refillers, re-importers)
-       Distributors (including retailers)
-       Producers or importers of articles that are explosive or that contain substances that are intentionally released or are on the Candidate List of Substances of Very High Concern
-       Researchers and developers of chemicals.

What will change?
The implementation of the new legislation means that there will be changes to the format of the safety data sheet (SDS). The most noticeable change will be Section 15 where Risk Phrases will be replaced by Hazard Statements, Safety Phrases will be replaced by Precautionary Statements, and there are new pictograms for labelling packages. See below. These new statements and labels will be moved from Section 15 to Section 2 of the new SDS.

Regulatory compliance is of paramount importance for all those within the solvents industry. The member companies of HSPA (the Hydrocarbon Solvents Producers Association) and OSPA (the Oxygenated Solvents Producers Association) are working to ensure that classifications are consistent, accurate and available within the compliance timeframe.

 In the case of HSPA CLP will be based on the hydrocarbon solvents naming convention for “groups” of hydrocarbons that have similar physical and chemical properties allowing a category approach to be used both for REACH registration and for CLP purposes. The concept was developed at the beginning of the REACH process in order to facilitate and streamline the substances´ identification out of the current EINECS identifiers more linked to petroleum refinery streams, and it has been endorsed by the European Chemical Agency (ECHA). 

Using the category approach has ensured that each recommended “new” classification is based on sound scientific evidence developed from the toxicological data that has been used in the REACH registration. This process is complete and has demonstrated clearly that, for the most part, the basis of the classifications will remain the same.

Since the work of the solvents´ industry´s CLP Team is closely aligned with the REACH process, solvent users can be assured that the revised classifications will be appearing on packages and updated material safety data sheets over the next few months. Initially safety data sheets must contain both the new and the old classifications for legal reasons, however, the package must only be labelled in accordance with the new requirements.

Where can I read more about CLP?
Further guidance is available on the ECHA homepage.  If you have any specific classification questions we advise you to contact your supplier.

Disclairmer:
“The CLP classifications  are based on the entries in table 3.1 of annex VI of the CLP regulation (EC N°1272/2008) , and are confirmed by the REACH substance information exchange forums (SIEFs) and the consortia compiling the registration dossiers for the substances. When necessary, a self-classification has been adopted. 

This information is to the best of the ESIG/ESVOC’s  knowledge and belief accurate and reliable as at the date indicated. However, no representation, warranty or guarantee is made as to its accuracy, reliability or completeness. It is the user’s responsibility to satisfy themselves as to the suitability and completeness of such information for their own particular use(s)”