Changes to Chemical Labels and SDS

DG Employment, Social Affairs and Inclusion

Changes to labels and SDS What is this training about? – Changes to the way that chemical hazards are communicated

How will I be affected? – New labels and symbols (pictograms) – Some changes to classifications

What might I need to do? – Review your risk assessments and update your risk management measures if necessary

Legislation on classification and labelling • Before being placed on the market, all chemicals must be – Classified to identify any intrinsic hazards – Labelled if hazardous according to strict rules with information on • Identity of the hazardous chemical(s) • What type of hazard there is • Safe use instructions

– Packaged safely

Legislation on classification and labelling • For many years these requirements have been driven by – The Dangerous Substances Directive 67/548/EEC (DSD) – The Dangerous Preparations Directive 1999/45/EC (DPD)

• These Directives are implemented in each member state through national legislation • This legislation is now being replaced by a new directly acting Regulation – The Regulation (EC) No 1272/2008 on Classification, Labelling and Packaging of Substances and Mixtures (the CLP Regulation)

What is CLP? • CLP adopts the UN Globally Harmonised System of Classification and Labelling of Chemicals (GHS) into the EU • GHS aims to improve worker and consumer protection, and facilitate global trade by providing • “... a common basis to define and classify chemicals according to their hazards and to communicate this information via labels and safety data sheets”

Timetable for transition to CLP

Substances

Mixtures

All substances classified and labelled according to CLP. Both CLP and DSD classifications on the SDS. 2 yr derogation, for stock already on the market May be classified and labelled according to either DPD or CLP. If labelled according to CLP, both DPD and CLP classifications must appear on the SDS.

All substances classified and labelled to CLP. Only CLP classifications need appear on the SDS

All mixtures classified and labelled to CLP. Only CLP classifications need appear on the SDS 2 yr derogation for stock already on the market

Classification • Classification identifies the type of hazard – e.g. flammable, toxic

• The severity of the hazard – e.g. very toxic, toxic, harmful

• Under CLP the type of hazards identified are mostly the same, but – they are split into more hazard classes and sub divisions or categories – different classification criteria and methods are used for some types of hazard, which may change the classification of some chemicals, or result in some chemicals being classified for the first time

Physical Hazards DSD/DPD • • • • •

Explosive Oxidising Extremely flammable Highly flammable Flammable

* New under CLP

CLP • • • • • • • • • • • • • • • •

Explosives Flammable gases Flammable aerosols Oxidizing gases Gases under pressure* Flammable liquids Flammable solids Self-reactive substances and mixtures Pyrophoric liquids Pyrophoric solids Self-heating substances and mixtures * Emits flamm. gases in contact with water Oxidizing liquids Oxidizing solids Organic peroxides Corrosive to metals*

Physical Hazards Explosive, Self Reactive Organic Peroxide Flammable Gases, Liquids and Solids; Pyrophoric, Self-Reactive, Self-Heating; Flammable Aerosols; Organic Peroxides; Emits Flammable Gas in Contact with Water Oxidizing Gases, Liquids and Solids

Gases under pressure

Corrosive to metals

Health hazards DSD/DPD

CLP

• • • • • • • • •

• • • • • • • •

Very toxic Toxic Harmful Corrosive Irritant Sensitising Carcinogenic Mutagenic Toxic for Reproduction

• •

Acute toxicity Skin corrosion/irritation Serious eye damage/eye irritation Respiratory or skin sensitisation Germ cell mutagenicity Carcinogenicity Reproductive toxicity Specific target organ toxicity – single exposure Specific target organ toxicity – repeated exposure Aspiration hazard

Health Hazards Acute toxicity - Very toxic (Fatal) - Toxic Corrosive (causes severe skin burns and eye damage) Serious Eye Damage

OR

Respiratory sensitiser Mutagen, Carcinogen, Reproductive toxicity Specific Target Organ Toxicity – Single Exposure Specific Target Organ Toxicity – Repeated Exposure Aspiration hazard Acute toxicity - Harmful Skin Irritation, Serious Eye Irritation, Skin Sensitiser Specific Target Organ Toxicity – Single Exposure - Respiratory Irritant , Narcotic

Environmental hazards DSD/DPD

CLP

•

•

Dangerous for the Environment

•

Hazardous to the Aquatic Environment Hazardous to the Ozone Layer

Acute Aquatic Toxicity Chronic Aquatic Toxicity

Dangerous for the ozone layer

Labelling Label elements under DSD/DPD • • • • •

Symbols Indications of Danger Risk Phrases Safety Phrases Additional labelling requirements

Label elements under CLP • • • • •

Pictograms Signal Word Hazard Statements Precautionary Statements Supplementary labelling information

New hazard pictograms Type of hazard The substance or mixture may cause serious longterm health effects, such as carcinogenicity or respiratory sensitisation

DSD/DPD Symbol

OR

Less serious health hazards such as irritation, skin sensitisation and less severe toxicity (harmful) Contains gases under pressure

No symbol under DSD and DPD

CLP Pictogram

DSD/DPD vs CLP Label Elements • Indications of Danger • Signal Words – Explosive – Danger – Oxidising – Warning – Extremely Flammable – Highly Flammable – Very Toxic – Toxic – Harmful – Corrosive – Irritant – Dangerous for the Environment

DSD/DPD vs CLP Label Elements • Risk Phrases – R11 Highly flammable R26 Very toxic by inhalation – R34Causes burns

• Safety Phrases – S7 Keep container tightly closed – S24/25 Avoid contact with skin and eyes – S36 Wear suitable protective clothing

• Hazard Statements – H225 Highly flammable liquid and vapour – H330 Fatal if inhaled – H314 Causes severe skin burns and eye damage

• Precautionary Statements – P233 Keep container tightly closed – P262 Do not get in eyes, on skin or on clothing – P280 Wear protective gloves/protective clothing/eye protection/face protection

Name, Address and Tel. No of Supplier

Chemical Name and Product Identifier

Acetone EC No. 200-662-2

ABC Chemicals Main Street Anytown Tel.: 0123 456 789

Danger

Pictograms

Highly flammable liquid and vapour. Causes serious eye irritation. May cause drowsiness or dizziness Keep away from heat/sparks/open flames/hot surfaces - No smoking. Avoid breathing vapours. Wear protective gloves/eye protection. IF IN EYES: Rinse cautiously with water for several minutes. Remove contact lenses, if present and easy to do. Continue rinsing. Store in a wellventilated place. Keep container tightly closed. Repeated exposure may cause skin dryness and cracking

500 ml Supplementary Information

Signal Word Hazard and Precautionary Statements

Nominal Quantity

Single Packagings • On single packagings, e.g. drums, IBCs labelled for both transport and CLP, suppliers may omit hazard pictograms if they duplicate the transport labels – Check all labels on the package to make sure all hazards are identified

Combined label for single packaging Proper Shipping Name and UN No.

Methanol UN1230 Transport Labels

XYZ Chemicals High Street New Town 0987 654 321

Methanol

Danger

603-001-00-X

Chemical Name and Product Identifier

Pictograms and Signal Word

Highly flammable liquid and vapour. Toxic if swallowed. Toxic in contact with skin. Toxic if inhaled. Causes damage to organs . Keep away from heat/sparks/open flames/hot surfaces . - No smoking. Do not breathe mist/vapours/spray . Wear protective gloves/protective clothing/eye protection. IF SW ALLOWED: Immediately call a POISON CENTER or doctor/physician. IF ON SKIN (or hair): Remove/Take off immediately all contaminated clothing. Rinse skin with water/shower. Store in a well-ventilated place. Keep container tightly closed.

Hazard and Precautionary Statements

Safety Data Sheets • Safety Data Sheets are required by REACH • Format revised to align with GHS – still 16 section format, but additional sub-headings introduced – Classification and labelling information now in Section 2 – For substances, and for mixtures which have already been labelled according to CLP, the classification and labelling of the product should be given for both the DSD/DPD and for CLP until 1 June 2015. – Many other changes to SDS as a result of REACH

Safety Data Sheets Classification according to both DSD/DPD and CLP for substances and for mixtures already labelled to CLP until 1 June 2015 Label information including any pictograms

Classification of component substances according to both DSD and CLP for mixtures until 1 June 2015

Why might the classification of a product change? • The classification for some substances and mixtures may increase (or decrease) in severity under CLP because: – The hazard data are still the same, but CLP classification criteria and methods result in a different classification – New hazard information has been identified, e.g. through REACH and the substance or mixture is more/less hazardous than previously thought – A mixture has been reformulated with different component substances that have different hazards

What to do now  Look out for new labels and safety data sheets  Make sure you understand and recognise the new label information  Check that your use of the substance or mixture is covered in section 1 of the SDS and any Exposure Scenarios, and is not advised against  Follow the advice provided on the new labels and in safety data sheets  Check whether the classification has changed  Evaluate the risks from your use of the substance or mixture and update workplace risk assessments if necessary  If you are an employer, communicate these changes to your employees  If you have any questions about the new label or safety data sheet, speak to your supervisor or the supplier

Further Reading Occupational Safety and Health and the CLP Regulation Guidance To Help Employers And Workers To Manage The Transition To The New System

Acknowledgements This publication is supported by the Community Programme for Employment and Social Solidarity - PROGRESS (2007-2013). This programme is managed by the Directorate-General for Employment, social affairs and equal opportunities of the European Commission. It was established to financially support the implementation of the objectives of the European Union in the employment and social affairs area, as set out in the Social Agenda, and thereby contribute to the achievement of the Lisbon Strategy goals in these fields. The seven-year Programme targets all stakeholders who can help shape the development of appropriate and effective employment and social legislation and policies, across the EU-27, EFTA-EEA and EU candidate and pre-candidate countries. PROGRESS mission is to strengthen the EU contribution in support of Member States' commitment. PROGRESS will be instrumental in: • • • •

providing analysis and policy advice on PROGRESS policy areas; monitoring and reporting on the implementation of EU legislation and policies in PROGRESS policy areas; promoting policy transfer, learning and support among Member States on EU objectives and priorities; and relaying the views of the stakeholders and society at large

For more information see: http://ec.europa.eu/progress. Furthermore, the production of this document by the RPA Consortium (Risk and Policy Analysts Ltd, Denehurst Chemical Safety Ltd, Milieu, Gillies Associates and Imperial College) was funded by the European Commission as part of a Study Service Contract to provide on Analysis and Evaluation of the Health, Social, Economic and Environmental Impact of a Possible Amendment of Certain EC Directives on Health and Safety at Work as a Result of the Adoption of Regulation (EC) No 1272/2008 (Contract number: VC/2010/0446). Document completed December 2011 Reproduction is authorised provided the source is acknowledged.