The chemical industry has come through the first stage of REACH (Regulation Evaluation, Authorisation and Restriction of Chemicals) without too much trauma. This is no time to relax though because the closely related (and confusing) CLP (Classification, Labelling and Packaging) Regulation EC 1272/2008 has followed closely behind.
What’s it about ?
There are already regulations to control dangerous chemicals. You may already be familiar with Materials Safety Data Sheets (MSDS), risk assessments under COSHH (Control of Substances Hazardous to Health) and warning labels such as red diamonds on packaging.
Most chemicals, however, are not well-understood. Out of 100 000 chemicals on the European market, only about 3 000 have been properly assessed for safety to human health and the environment. – a problem that REACH seeks to address.
Nothing ever happens in a political vacuum and international trade barriers are a powerful driving force. After several years of negotiation there is a new system to classify and label dangerous chemicals – GHS (Globally Harmonised System). This will be put into effect by the CLP Regulation.
Who is affected ?
Any company that supplies a dangerous chemical or mixture to a professional user. Typical products could include paints, adhesives, printing inks, cleaning materials. If you already have to provide safety information, you are definitely affected.
What does it mean in practice and when ?
It depends on the product – is it a single substance or a mixture ?
If it’s a single substance :
From 1 December 2010 – Classify your products according to both the old CHIP (Chemical Hazards Information and Packaging) Regulation and the new CLP (Classification, Labelling and Packaging) Regulation.
You need to look at risks to safety such as fire, health and the environment and update your safety data sheets to the legally required format.
Label the product according to CLP. You don’t have to re-label a product that’s already on the shelf
From 1 June 2015 – Classify, label and package according to CLP only.
If you manufacture the products yourself or import them from outside Europe you must also – by January 3rd - inform ECHA (European Chemicals Agency) of the classification.
Unlike REACH, there is no exemption for small manufacturers/importers below 1 tpa.
If it’s a mixture :
Until 1 June 2015 – Classify, label and package according to CHIP. You can classify, label and package under CLP if you prefer but you must also include the CHIP classification
1 June 2015 – Classify, label and package according to CLP.
If your mixture is classified as hazardous, you must – by January 3rd – notify ECHA of the hazardous ingredients that exceed thresh-hold concentrations.
Where can I find further information ?
As members of the Chemical Hazards Communication Society we can advise if your safety information meets legal requirements, classify your products and update your safety data sheets.
We also assist companies who want to take a whole-business approach to REACH, dealing with risks and opportunities as well as the regulation issues, if you would like to discuss any issues, then please done hesitate to contact us.
Paul Forsythe
Alemare Solutions Ltd
5 London End
Irchester
Wellingborough
Northants
NN29 7BH
Tel: 01933 356422
Email : info@alemare-solutions.com
http://www.alemare-solutions.com/reach_services.php
Reg: 05786053 (England)
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