How to understand the new labelling of chemicals GHS and CLP: Useful links

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  • After a preliminary analysis of the systems already existing in different countries (and in order not to start all over again) and after a long elaboration, a first complete version is published in 2002. Successive amendments are included in the revised second version of GHS, published in 2007 so that the system is fully operational in 2008. Actually GHS is to be applied step by step in Europe since January 2009.

    All the files of this huge document are available on the UNECE website:
    http://www.unece.org/trans/danger/publi/ghs/ghs_rev02/02files_e.html

    According to the schedule planning its revision and updating every two year, GHS was revised and updated in July 2009. The main modifications consisted in the definition of sub-categories in the hazard class «respiratory and skin sensitization», the revision of the classification criteria for long-term hazards (chronic toxicity) to the aquatic environment; and at last the creation of the very expected new hazard class about the damages to the ozone layer, resulting from the precocity of Europe in this field.

    The complete 462 page documentation can be downloaded from the following webpage:

    http://www.unece.org/trans/danger/publi/ghs/ghs_rev03/03files_f.html.

  • As mentioned above, since 2009, GHS has introduced a 28th hazard class, and thus has converged with CPL which, in the name of Europe, had already taken into account the “Hazard to the ozone layer”.

    The environmental classification of mixtures is ruled by very detailed regulations taking account of the sum of constituents, dilution and multiplication factors for the most toxic constituents. All the details are to be found in the complete CLP 1272 regulation on the following website:

    http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2008:353:0001:1355:EN:PDF

  • If Annex VI possesses obvious advantages, it has limits too. Annex VI concerned only the substances officially targeted by a decision of European Harmonization, i.e. those considered as worrying priorities.
    They are, actually, 4136. However, all the substances present in the European area account for more than 105 000 registrations according to the very official website «Institue for Health and Consumer Protection» – IHCP (ex European Chemical Bureau).  Except the 4136, the classification of which generated a specific obligation of labelling imposed by the EU, the responsibility of labelling of any other substance was entirely left to its manufacturers, dealers… Such substances are said «self-classified».  In the regime of self-classifying, the person in charge of of the label must still follow methodically the technical instructions described with great precision in the CLP.

    When moving to CLP, only this official part (integrating former ATPs) was transferred to annex VI, called European harmonized list, in the new text CLP N° 1272/2008. The annex VI may be downloaded from the IHCP website:
    http://ecb.jrc.ec.europa.eu/esis/index.php?PGM=cla 

  • Globally, the tables at the end of CLP regulation and IHCP link will greatly help the transition towards a new labelling for more than 4000 «preoccupying» common substances. Thanks to the registration of a large number of products, REACH will soon give some new useful complementary data. They will be accessible in the future on ECH web site (European Chemical Agency: http://echa.europa.eu/)

  • These changes come from the GHS recommendations in the text United Nations Economic Commission for Europe (UNECE) as well as from the REACH regulation (see paragraph 4.9 below). Therefore it isn’t an integral part of the European regulation CLP 1272/2008. The complete text associated with the 2009 issue of GHS is available on the following website:

    http://www.unece.org/trans/danger/publi/ghs/ghs_rev02/English/08e_annex4.pdf
    Annex IV, GUIDANCE FORTHE PREPARATION OF SAFETY DATA SHEETS

  • In Europe, the transport of dangerous materials is under the rule of the European Agreement concerning the international carriage of Dangerous goods by road. Applicable since 1st January 2009, the complete texts are to be downloaded from the following address:

    http://www.unece.org/trans/danger/publi/adr/adr2009/09ContentsF.html

    For transport by train, please check in RID (Regulations concerning the International carriage of Dangerous goods by rail)

  • The following link directs to the ECHA website: http://guidance.echa.europa.eu/safety_sheet_fr.htm
    One can download the “Guidance on Information Requirements and Chemical Safety Assessment -PATHFINDER” at the address:

    http://guidance.echa.europa.eu/docs/guidance_document/information_requirements_en.htm#D

    The complete « Guidance for downstream users » published by ECHA can be downloaded, in English from the website:

    http://guidance.echa.europa.eu/docs/guidance_document/du_en.pdf?vers=29_01_08

    Globally of all the new points brought by REACH in matter of MSDS, we will insist on the two following notions: Chemical Safety Report and Exposure Scenarii.

Exposure scenarios

Exposure scenarios must be prepared to cover to cover all "identified uses"

“Exposure scenarios are also a communication tool for operating conditions and risk management throughout the supply chain, insofar as the relevant exposure scenarios are attached to safety data sheets provided to downstream users and distributors”.

You may find a short synthesis in English on:

http://guidance.echa.europa.eu/exposure_scenarios_en.htm

All the required information is in the “Guidance on information requirements and chemical safety assessment
Part D: Exposure Scenario Building” (75 pages).

It can be downloaded from the ECHA website:  

http://guidance.echa.europa.eu/docs/guidance_document/information_requirements_part_d_en.pdf

The tool is ready to use. It is the role of each of us to make it hers/his, through work and tenacity, so that we all live in an always more controlled and safer world of chemistry. The authors wish that this GHS Brochure contributes to this achievement and are open to reader’s comments and suggestions (This email address is being protected from spambots. You need JavaScript enabled to view it.).