Changes to Chemical Labels and SDS - Speaker s notes

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1 Slide 1 Changes to Chemical Labels and SDS Title slide. Slide 2 Changes to labels and SDS This presentation is intended to help those who need to give information about changes to the way that chemical hazards are communicated to their employers, employees or colleagues. The presentation will explain how you may be affected, and what you might need to do as a result. Slide 3 - Legislation on classification and labelling All chemicals have to be assessed to identify if they are hazardous according to strict definitions before they can be placed on the market this is called classification. If the chemicals are found to be hazardous, then information about the hazards has to be communicated to users through labels and safety data sheets. Hazardous chemicals also have to be packaged so that they can be supplied safely. Slide 4 - Legislation on classification and labelling For many years, classification and labelling requirements have been driven by two European Directives - The Dangerous Substances Directive 67/548/EEC (DSD) and The Dangerous Preparations Directive 1999/45/EC (DPD). You may not have heard of these Directives, as they had to be transposed into national legislation by each EU Member State, for example they were implemented in the UK through The Chemicals (Hazard Information and Packaging) for supply Regulations (CHIP) These two directives are now being replaced by a new regulation The Regulation (EC) No 1272/2008 on Classification, Labelling and Packaging of Substances and Mixtures, which is known as CLP. As CLP is a directly acting Regulation, there is no need to transpose it into national legislation, although enforcement legislation may still be required in each Member State. Slide 5 What is CLP The UN Globally Harmonised System of Classification and Labelling introduces a common system of classification and labelling that will be used for chemicals around the world. Other countries that have adopted the GHS, or are in the process of doing so, include New Zealand, Japan, China and the US. Slide 6 - Timetable for transition to CLP CLP is being introduced over a seven year period to allow chemical suppliers time to implement the changes, and for chemicals to work through the supply chain. This means that both old and new styles of labels may both be found for some time to come, and all workers who come into contact with chemicals will need to understand them. 1

2 Slide 7 - Classification When introducing the GHS into the EU through the CLP Regulation, the European Commission took advantage of various options to try and keep the scope of CLP as close as possible to the scope of the DSD and DPD. However, there are some differences. Firstly, there are a lot more hazard classes under CLP than under DSD and DPD. In most cases, this does not mean that new hazards are being identified, but that the hazards are being divided up in a new way. CLP also introduces more subdivisions and categories within each hazard class. In some cases, the different classification criteria and methods may mean that chemicals that were not previously classified as hazardous are no classified, or that hazardous chemicals are classified in a different way or in a more severe hazard category. Slide 8 Physical hazards Physical hazards are hazards which can cause harm to people through physical effects such as explosion and fire. Under DSD/DPD there were 5 hazard categories for physical hazards, under CLP there are 16 hazard categories. In most cases, this is becausethe same chemicals have been divided up in a different way, but there are a few new hazard classes, indicated by an asterisk (*). These extra hazard classes may be familiar as they are the same hazard classes that are used for the transport of dangerous goods. The physical hazards classification criteria are aligned with those for transport (responsibility for developing this part of the GHS was given to the UN Transport of Dangerous Goods committees). Slide 9 Physical hazards This slide shows the new CLP pictograms, the old DSD/DPD symbols, and the hazard classes to which they are assigned. The two new pictograms (gases under pressure and corrosive to metals) do not have a corresponding DSD/DPD symbol, as these are new hazard classes introduced in CLP. Slide 10 Health hazards Chemicals classified for health hazards may cause harm if they come into contact with skin, are ingested or inhaled. Harm may occur after a short exposure, e.g. corrosive chemicals, or after long term exposure, e.g. carcinogens (chemicals which may cause cancer). Under DSD and DPD, there are 9 hazard classes for health hazards. Under CLP, there are 10 hazard classes. No new hazards are covered the hazard classes are just arranged differently. As with the physical hazards, the CLP hazard classes are further subdivided into several hazard categories, and the boundaries for these hazard categories may be different under CLP to those under DSD & DPD. This will result in the classifications of some chemicals changing to a more or less severe hazard category. Changes in the way that classifications for mixtures are calculated may also mean that more mixtures may be classified as hazardous, or classified in a more severe hazard category. 2

3 Slide 11 Health hazards This slide shows the new CLP pictograms, the old DSD/DPD symbols, and the hazard classes to which they are assigned. Two new pictograms are introduced for health hazards. The silhouette pictogram indicates that the chemical may cause serious long term health effects. For less severe health effects, the exclamation mark pictogram replaces the St Andrew s cross. Note that for serious eye damage, the corrosive pictogram is now used (under DSD and DPD the St Andrew s cross was used). Slide 12 Environmental hazards Chemicals classified as hazardous to the environment may cause harm to aquatic organisms (fish, invertebrates, aquatic plants) or to the ozone layer. The classification criteria for environmental hazards are similar to those under DSD and DPD, and there are not expected to be many changes to the chemicals that are classified and labelled. Slide 13 Labelling This slide shows the label elements which you can expect to find on labels under DSD and DPD, and under CLP. We will look at these in the next few slides. Slide 14 - New hazard pictograms This slide is a reminder of the three new pictograms that have been introduced under CLP: - The silhouette pictogram indicates that the chemical may cause serious long term health effects. - For less severe health effects, the exclamation mark pictogram replaces the St Andrew s cross. - The gas bottle indicates gases under pressure (compressed gases, liquefied and refrigerated gases, and dissolved gases) Slide 15 DSD/DPD vs CLP Label Elements CLP uses a system of Signal Words instead of the Indications of Danger used under CLP. Two levels of signal words are used: - Danger for more severe hazards - Warning for less severe hazards Only one signal word should appear on a label, so if a chemical has more than one hazard, the most severe signal word is used. The CLP signal word system is simpler, though less informative than the Indication of Danger. However, the information in the Indication of Danger will be conveyed through the Hazard Statements, so no information should be lost. 3

4 Slide 16 - DSD/DPD vs CLP Label Elements CLP uses a system of Hazard Statements and Precautionary Statements instead of Risk Phrases and Safety Phrases. The Hazard Statements and many of the Precautionary statements convey similar information to the Risk and Safety Phrases. There is a greater range of Precautionary Statements, covering Preventive Measures, Emergency Response, Storage and Disposal. Slide 17 Example label This slide shows an example label for a common chemical. Note that under CLP a greater number of Precautionary Statements may be assigned to a chemical, and suppliers will normally choose up to 6 of the most relevant for the intended uses of their product. This may mean that in some cases, suppliers may choose different Precautionary Statements for the same chemical. Slide 18 Single Packagings For single packagings (drums, IBCs, etc,) it is important to check both supply and transport labelling, as suppliers may omit some pictograms if they duplicate transport labels. Slide 19 Combined label for single packaging An example where a supplier has omitted the flammable (GHS02) and toxic (GHS06) pictograms from the supply label, as they duplicate the class 3 and class 6.1 transport labels. Slide 20 Safety Data Sheets SDS are required by the REACH Regulation. The format is set out in Annex II of REACH, and the format has been recently amended to align with the GHS. The new format now requires the inclusion of 47 sub-headings. All SDS should be in the new format by 1 Dec Section 2 should now include classification and labelling (moved from section 15). For substances and for mixtures already classified to CLP, classification needs to be shown for both DSD/DPD and CLP until 1 June After this, only CLP needs to be shown. REACH has made many other changes to SDS, including more detailed information about recommended uses and uses advised against, and the addition of exposure scenarios for hazardous substances manufactured or imported above 10 tonnes per year. Slide 21 Safety Data Sheets The example shows where to find classification and labelling information in the new format. 4

5 Slide 22 - Why might the classification of a product change? The introduction of both REACH and CLP will result in suppliers undertaking a great deal of work to identify hazard data and classify chemicals. In some cases, this may result in changes in severity of the classification for a chemical. To make sure that risk management measures are appropriate (and to avoid possibly introducing unnecessary risk management measures) it is important to understand why the change in classification has taken place. Where the classification has changed as a result of differences in the boundaries between classifications in CLP, then you should recognise that although the classification and labelling has changed, the intrinsic hazards of the chemical have not changed. If existing risk management measures (RMM) are providing adequate protection, then there should not be any need to change them. Of course, if your existing RMM are not adequate you should update them without delay. REACH registration requirements will require that suppliers review existing information, and generate new information where necessary about the properties of chemicals. This may result in new hazards being identified for chemicals. In this case, you will need to review your RMM to see if they are adequate or need to be updated. Some suppliers formulate their products so that they fall below classification thresholds for various properties, so as to avoid undesirable classifications for their intended markets. Changes to the way that mixtures are classified under CLP may mean that some suppliers will need to reformulate their products to continue to avoid such classifications. This may mean that you need to review your RMM to check that they are still suitable for the new formulation. For example, a change in solvent may mean that the gloves you are using no longer provide adequate protection and a different type of glove may be required. Slide 23 - What to do now These tips are designed to help you manage the changes in labels and safety data sheets and identify when you may need to take action to review the risk management measures you use to protect workers from chemical hazards. Slide 24 Further reading For more information about how CLP may affect worker protection legislation, please read the guidance document: Occupational Safety and Health and the CLP Regulation Guidance To Help Employers And Workers To Manage The Transition To The New System <<link to guidance document>> 5

6 This presentation is supported by the Community Programme for Employment and Social Solidarity - PROGRESS ( ). This programme is managed by the Directorate-General for Employment, social affairs and equal opportunities of the European Commission. It was established to financially support the implementation of the objectives of the European Union in the employment and social affairs area, as set out in the Social Agenda, and thereby contribute to the achievement of the Lisbon Strategy goals in these fields. The seven-year Programme targets all stakeholders who can help shape the development of appropriate and effective employment and social legislation and policies, across the EU-27, EFTA-EEA and EU candidate and pre-candidate countries. PROGRESS mission is to strengthen the EU contribution in support of Member States' commitment. PROGRESS will be instrumental in: providing analysis and policy advice on PROGRESS policy areas; monitoring and reporting on the implementation of EU legislation and policies in PROGRESS policy areas; promoting policy transfer, learning and support among Member States on EU objectives and priorities; and relaying the views of the stakeholders and society at large For more information see: Furthermore, the production of this document by the RPA Consortium (Risk and Policy Analysts Ltd, Denehurst Chemical Safety Ltd, Milieu, Gillies Associates and Imperial College) was funded by the European Commission as part of a Study Service Contract to provide on Analysis and Evaluation of the Health, Social, Economic and Environmental Impact of a Possible Amendment of Certain EC Directives on Health and Safety at Work as a Result of the Adoption of Regulation (EC) No 1272/2008 (Contract number: VC/2010/0446). Document completed December 2011 Reproduction is authorised provided the source is acknowledged. 6