Uniform regulations for hazardous substances and mixtures throughout Europe
For safety reasons, hazardous substances and mixtures must be correctly classified and labelled before being placed on the market or used in the workplace. The respective rules can be found in the European Regulation (EC) No 1272/2008, the so-called CLP Regulation. It sets uniform standards for all member states for the classification, labelling and packaging of substances and mixtures.
The CLP Regulation is based on the United Nations (UN) recommendation on the so-called "Globally Harmonised System" (GHS), which dates back to the 1992 Sustainability Conference in Rio de Janeiro. The UN GHS provides the framework for uniform global standards for the safe handling of hazardous substances and mixtures and sets the rules for sharing the necessary information in the supply chain. Europe is one of the first regions in the world to put the UN GHS framework into practice.
Until 2008, the regulations on the classification and labelling of hazardous substances and mixtures in the EU were based on two European directives, the Substances Directive (Directive 67/648/EEC) and the Preparations Directive (Directive 1999/45/EC). 1 June 2017 marks the end of the transitional period for the introduction of the CLP Regulation, since then no containers with the "old" labelling may be placed on the market. However, stocks may still be used up within the company or bear the old labelling under certain conditions if it is ensured that the old and new classification and labelling are understood by the workers, see also TRGS 201 "Classification and labelling for activities involving hazardous substances".
The UN GHS will also be subject to changes and adaptations in the future. Within the framework of 2-year programmes, current developments are taken up for improvement and are integrated if necessary. This has two practical consequences: on the one hand, the CLP Regulation has to be adapted to the latest technical status of the UN-GHS. This is done in each case with the help of a so-called ATP (adaptation to technical progress). On the other hand, many criteria are formulated comparatively openly and require expert knowledge for evaluation. This opens up the scope, but can also trigger uncertainty. Assistance with such problems is provided by the REACH-CLP-Biocide Helpdesks of the federal authorities. ECHA offers clarifications and examples related to the classification criteria of the CLP Regulation with its Guidance on the Application of the CLP Criteria.
The provisions of the CLP Regulation have many similarities with the previous legislation, in particular the classification is in principle structured in the same way.
In detail, however, there are quite a few deviations. For example, the change in the hazard pictograms is obvious: in the past, the black symbols were backed by an orange square; today, they are placed on the background of a white rhombus with a red border. The symbols themselves have also been modified.
With classification, substances and mixtures are assigned certain hazard classes and hazard categories based on relevant criteria according to their hazardousness. While the hazard classes indicate the nature of the hazard, the hazard categories are used for grading within the classes. With the new regulation, the EU currently has 17 classes for physical hazards, ten for health hazards and two classes for environmental hazards. Especially for mixtures, some criteria have been tightened. According to the CLP Regulation, for example, irritant or corrosive substances in a mixture trigger the classification of the mixture as hazardous in significantly lower concentrations as before. Details on the classification criteria can be found in Annex I, Parts 2-5 of the CLP Regulation.
Relevant labelling elements are then used to communicate the hazards via the label and the safety data sheet. The labelling includes:
The signal word is a new element and should be taken seriously for an initial assessment: the signal word "Danger" indicates particularly serious properties. Some of the nine pictograms are also new. In particular, GHS08 Health hazard, the so-called "torso", deserves special attention. This pictogram, in combination with the signal word "Danger", signals very serious damage to health with delayed progression. This combination is used, for example, to indicate carcinogenic properties. Overall, the new label contains more information than before, especially when it comes to the allocation of safety information, and can thus appear overloaded. Rules on how to counteract the overload of information can be found in Articles 26 - 28 of the CLP Regulation and in the ECHA Guidance on Labelling and Packaging. Exceptions to labelling and packaging requirements for special or small packaging are facilitated by Article 29 in combination with Annex I Part 1 of the CLP Regulation, which are specified in the above-mentioned ECHA Guidance.
You can find further help and explanations on the CLP Regulation via the links on this page. You can also order information material, such as the GHS memo card "Hazardous substances compact", which explains the meaning of the new symbols, and posters on the Globally Harmonised System (GHS) in the EU.
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