COSHH, CLP and REACH
Two new European Regulations are already having an impact on the way chemicals are supplied, packaged and labelled.
CLP Regulation
The European Regulation (EC) No 1272/2008 on classification, labelling and packaging of substances and mixtures – the CLP Regulation – came into force in all EU member states, including the UK, on 20 January 2010. The CLP Regulation:
- adopts in the EU the Globally Harmonised System (GHS) on the classification and labelling of chemicals;
- applies directly in all EU member states. This means that no national legislation is needed;
- is overseen by the European Chemicals Agency (ECHA);
- replaced the Chemicals (Hazard Information and Packaging for Supply) Regulations 2009 – CHIP on 1 June 2015.
More detail can be found here:
The intention of the CLP Regulation is very similar to CHIP – substances and mixtures that are placed on the market should be classified, labelled and packaged appropriately. But because CLP adopts the GHS, in time, the same classifications and labelling will be used throughout the world.
A few changes to look out for
New hazard pictograms
Although the CLP hazard pictograms are very similar to the CHIP hazard symbols, they have a new shape, new design and a new colour. A brief description is given here for information purposes only.
Acute toxicity (severe)
Harmful skin irritation, serious eye irritation, acute toxicity (harmful)
Flammable gasses, flammable liquids, flammable solids, flammable aerosols, organic peroxides, self-reactive, pyrophoric, self-heating, contact with water emits flammable gas
Explosive, self reactive, organic peroxide
Harmful to the environment, hazard to the aquatic environment
Oxidising gases, oxidising liquids, oxidising solids
Respiratory sensitiser, mutagen, carcinogen, reproductive toxicity, systemic target organ toxicity, aspiration hazard
Corrosive (causes severe skin burns and eye damage), serious eye damage
Hazard statements
New hazard statements will replace the CHIP risk phrases.
Precautionary statements
New precautionary statements will replace the CHIP safety phrases.
Signal word
The CLP introduces a new requirement for labelling – a signal word, either "warning" or "danger" depending on the severity of the hazard.
New duties
But there are also new duties like notification the new Classification and Labelling Inventory.
CLP guidance
ECHA oversees the CLP Regulation and has published a suite of guidance to help you comply with the Regulation. ECHA's guidance[61]
You are encouraged to look at this guidance and to understand your new and changing duties.
UK CLP Helpdesk
Further help can be provided by the UK's national CLP Helpdesk: UKREACHCA@hse.gov.uk
REACH is a European Union Regulation concerning the Registration, Evaluation, Authorisation & restriction of CHemicals.
REACH aims to fill a gap in what we know about the chemicals used every day in industry and in consumer products. It takes a broad view of chemical use, and places new duties on businesses depending on where they sit in the supply chain.
One of the main new systems set up by REACH is called 'Registration'. Companies who manufacture chemical substances or import them into Europe – either on their own or mixed together to make chemical products - are at the top of the European supply chain. These companies have to 'register' a dossier of technical information about each substance they manufacture or import above a tonne a year with the ECHA in Helsinki.
If you buy your chemical within Europe, or in quantities below a tonne a year, you will not have to take part in the new REACH 'Registration' system.
REACH should result in more information being passed down the supply chain to users – for example safety data sheets will give more information about the exposure scenarios and risk management measures that should be taken when using a product.
In time, REACH will result in some particularly hazardous substances being taken out of use altogether, and some will have to be specifically 'authorised' for use.
REACH is a complex new system, and companies who manufacture, import, sell, or use chemicals should find out more.
What Businesses need to do
- Plan for the effects of REACH and CLP
- Understand your position in the supply chain and take any appropriate action
- Understand the potential impact of any changes in classification
- Ask your supplier for feedback
- Check the information on the safety data sheet
- Make sure your risk assessment is up to date
You can find more information on the REACH[62] website