A symbol of change

The chemicals industry is currently going through one of the most dramatic periods of change in its history. Here Simon Robinson explores how suppliers and users of chemicals need to prepare for the transition from the current CHIP system to the CLP regulations, which will implement the United Nations Globally Harmonised System (GHS) for classifying and labelling chemicals

THE UNITED Nations’ Globally Harmonised System of Classification and Labeling of Chemicals or GHS is an internationally agreed upon system set to replace the various different classification and labelling standards used in different countries. It is contained within the UN GHS “Purple Book”, which is not a formal treaty but a non-legally binding international agreement that provides countries with a regulatory framework to develop or modify existing programmes.

Countries (or trading blocks) must create local or national legislation to implement the GHS. Within Europe, for example Regulation EC 1272/2008 Classification, Labelling and Packaging of Hazardous Substances and Mixtures (CLP) has been developed. The proposed new regulation will replace: • the Dangerous Substances Directive (67/548/EEC) and • the Dangerous Preparations Directive (1999/45/EC).

These directives have been implemented in the UK as the Chemicals Hazard Information and Packaging for supply Regulations (CHIP). These CHIP regulations will be fully repealed in 2015 and replaced with a new set of regulations, which are likely to be called CHIP 4.

The GHS will use consistent criteria for classification and labeling on a global level. Development began at the United Nations Rio Conference in 1992, when the International Labour Organization (ILO), the Organisation for Economic Co-operation and Development (OECD), and various governments and stakeholders came together at the United Nations. The targets of GHS are to enhance protection to human health and the environment by: • Providing an internationally comprehensible system for hazard communication. • Providing a recognised framework for those emerging nations without an existing system. • Facilitating international trade in chemicals whose hazards have been properly assessed and identified on an international basis. • Reducing the need for animal testing and evaluation of chemicals.

GHS, a new system based on the various regulatory frameworks already in existence, harmonises the very successful UN system for Transportation of Dangerous Goods (“Orange Book”).

It is accepted that there will be teething problems and anomalies, which will be ironed out with refinements and the introduction of more comprehensive guidance documentation. Preparing for the new CLP regulations will require significant retraining at all levels of the supply chain, from the industrial regulatory experts and chemical operators down to the consumers. The visual impact of CLP will be very apparent. Orange/black “hazard symbols” will be replaced by red/black diamonds called “pictograms”.

Risk and Safety phrases (R and S phrases) are now replaced by Hazard and Precautionary statements. Hazard statements are separated into H200s  Physical hazards; H300s, Health hazards; and H400s, Environmental hazards. There is a more comprehensive coverage of hazardous properties and many of the phrase although have a similar meaning are worded differently, for example: “R28 Toxic if swallowed.” is replaced by “H300 Fatal if swallowed.” “R42 May cause sensitiation by inhalation.” Is replaced by “H334 May cause allergy or asthma symptoms or breathing difficulties if inhaled.”

Substances

Period	CLP - Regulations	CHIP (67/548)
Jan 2009 - 30 Nov 2010	*
1 Dec 2010 - 1 June 2015	**

**Substances classified, labelled and packaged according to CHIP (67/548) and already placed on the market before 1 December 2010 are not required to be relabelled until after 1 December 2012.

                                                                           Mixtures

Period	CLP - Regulations (GHS)	CHIP (67/548 & 1999/45/EC)
Jan 2009 - 30 Nov 2010	*
1 Dec 2010 - 1 June 2015	**

**Mixtures classified, labelled and packaged according to CHIP (1999/45) and already placed on the market before 1 December 2015 are not required to be relabelled until after 1 December 2017.

Precautionary statements are separated into a P100s for General; P200s for Prevention; P300s for Response; P400s for Storage; and P500s for Disposal. The precautionary phrases are far more detailed and are allocated according to the relevant hazards. A global signal word of either “Danger” or “Warning” is assigned to the high hazard categories. Apart from the obvious change in the actual symbols used, products with lower hazard will attract a pictogram. There are likely to be more hazard statements and a “signal” word. Precautionary statements will increase dramatically, as there is still currently little guidance on the order of precedence.

Companies having to redesign labels will clearly have a serious challenge to ensure that the labels are compliant and contain all the information in a readable format.

Important dates for the implementation of CLP are the CLP regulation entered into force on 1 January 2009, the EC directives (67/548/EC and 1999/45/EC) will be repealed with effect from 1 June 2015 and the target date for Classification, Labelling and Packaging of Substances is 1st December 2010.

Until 1 June 2015 the classification of substances according to both the EC directives and the CLP regulation needs to be shown in the safety data sheet (SDS), when the product is classified and labelled according to the CLP regulation. This means that the classification of substances according to the EC directive will be available throughout the whole transition period until 1 December 2015. The target date for classification, labelling and packaging of mixtures is 1 June 2015.

For mixtures, there is a provision to use the current EU Directive 1999/45/EC until 30 May 2015. Using the CLP regulation before this date will require the current EU Classification to be used on the SDS. Substances and mixtures already placed on the market (e.g. in a warehouse, on the shelf) need not be relabelled or repackaged according to the CLP regulation until two years later i.e. for substances on 1 December 2012, for mixtures on 1 June 2017.

United Nations Globally Harmonised System of Classification and Labelling of Chemicals (GHS) is contained within the “Purple Book”. This was first published in 2003 and is revised every two years. The UN work programmes continue to be developed and to refine the UN GHS in biennial work programmes.

The UN GHS Subcommittee last met in December 2008 in Geneva, where the following items were amongst those topics for discussion

• Aerosol flammability • Combined hazard and precautionary statements • Labelling of small packages • Development of criteria for the classification and labelling of substances hazardous to the terrestrial environment • Differential between strong and weak sensitisers. The UN website at http://www.unece.org is regularly updated with the latest GHS developments.

CLP Pictogram	Number	Hazard Class (CLP)	CHIP Symbol
	GHS-01	Explosives Self-reactive substances and mixtures, types A, B Organic peroxides, types A,B	Explosive
	GHS-02	Flammable gases, aerosols, liquids or solids Self reactive substances and mixtures Pyrophoric liquids and solids Self-heating substances and mixtures Substances and mixtures, wich in contact with water emit flammable gases Organic peroxides	Highly/Extremely flammable
	GHS-03	Oxidising gases, liquids and solids	Oxidising
	GHS-04 NEW	Compressed gases, liquids and solids Liquefied gases Refrigerated liquefied gases Dissolved gases	No current symbol
	GHS-05	Corrosive to metals Skin corrosion Severe eye damage
	GHS-06	Acute toxicity (Cat 1 - 3)	Toxic/Very       Harmful  Toxic
	GHS-07 NEW	Acute toxicity (Cat 4) Skin and eye irritation Skin sesitisation specific target organ toxicity Respiratory tract irritation Narcotic effects	Harmful/Irritant
	GHS-08 NEW	Respiratory sensitisation Germ cell mutagenicity Carcinogenicity Reproductive toxicity specific target organ toxicity Aspiration hazard	No current specific symbol Use either
	GHS-09	Hazardous to the aquatic environment	Dangerous for the environment