Since the 1st June 2015 the Classification, Labelling and Packaging (CLP) Regulation applies in full to Ireland. CLP is a European Union regulation which aligns the European Union system of classification, labelling and packaging chemical substances and mixtures to the Globally Harmonised System (GHS). It is expected to facilitate global trade and the harmonised communication of hazard information of chemicals and to promote regulatory efficiency. The CLP Regulation adopts the United Nations’ Globally Harmonised System on the classification and labelling of chemicals (GHS) across all European Union countries, including Ireland. The regulation requires companies to appropriately classify, label and package their substances and mixtures before placing them on the market. It aims to protect workers, consumers and the environment by means of labelling which reflects possible hazardous effects of a particular chemical. It also takes over provisions of the REACH Regulation regarding the notification of classifications, the establishment of a list of harmonised classifications and the creation of a classification and labelling inventory. How does CLP effect companies? If you are a supplier of chemicals, you must classify, label and package your substances and mixtures in accordance with the CLP Regulation. Your obligations depend upon your role in the supply chain. Suppliers may have one or more of these roles:
- Manufacturer of substances or mixtures
- Importer of substances or mixtures
- Producer of specific articles
- Downstream user, including formulator and re-importer
- Distributor, including retailer
All substances and mixtures must be classified, labelled and packaged in accordance with CLP by 1st June 2015. However, for mixtures already placed on the market on 1st June 2015 with the Dangerous Substances Directive labels (old GHS Symbols) they do not have to relabelled or repackaged in accordance with CLP until 1st June 2017. Labelling: Suppliers must label a substance or mixture contained in packaging according to CLP before placing it on the market either when:
- A substance is classified as hazardous.
- A mixture contains one or more substances classified as hazardous above a certain threshold.
CLP defines the content of the label and the organisation of the various labelling elements. It is harmonised in order to develop a single, globally harmonised system to address classification of chemicals, labels, and safety data sheets. The label includes:
- The name, address and telephone number of the supplier
- The quantity of a substance or mixture in the packages made available (unless this quantity is specified elsewhere on the package)
- Product identifiers
- Where applicable, hazard pictograms, signal words, hazard statements, precautionary statements and supplemental information required by other legislation.
Small packaging exemptions: There are certain exemptions for substances and mixtures contained in packaging that is small (typically less than 125ml) or is otherwise difficult to label. The exemptions allow the supplier to omit the hazard and/or precautionary statements or the pictograms from the label elements normally required under CLP. Principles of Safe Storage A manufacturers’ Safety Data Sheet (SDS) will be available for every chemical agent purchased and stored. These should be supplied when the chemical agent is first supplied. If the original cannot be found a replacement can be obtained from the supplier or found via the Internet. The SDS will set out the manufacturer’s identification of the hazards and risk from the agent and detail storage arrangements and particular hazards. Emergency arrangements and procedures onsite should include;
- Methods of reporting an emergency situation.
- A method for calling the emergency services.
- Providing the emergency services with details of the chemical substances and agents and quantity in store.
- The provision of suitable fire fighting equipment to help workers and others get to a place of safety.
- Spillage procedure (consider providing a spill kit).
- Emergency personal protective equipment.
The European Chemicals Agency (ECHA), the driving force among regulatory authorities in implementing the EU's ground breaking chemicals legislation is available online About Us - ECHA You need to ensure your Safety Management Systems are up to speed - Call us at Peninsula Business Services (Ireland) Ltd for more details on 0818 923 923.