About The New Chemical Hazard Classification
System For Product Labelling
Classification, Labelling & Packaging (CLP) Regulations Effective 1st June 2015
RP Adam Ltd: [email protected]
Issue 1: 31st March 2015
Keeping You Up To Speed
With Changes To Labelling
This document is the first issue in a series which will be
distributed regularly to keep RP Adam staff, distributors and
customers up to speed with changes to product labelling.
Over the course of the next two months we will be working
tirelessly to ensure ALL RP Adam Ltd product labels are revised to
comply with the new CLP Regulations for the 1st June 2015
deadline.
If there are any questions at any stage please refer them to our
email address: [email protected]
As part of this process we intend for the new product labels to contain more product
information, application advice and detailed health & safety information than ever before, so
that the chemical container almost becomes a Product Guidance Sheet in itself.
We hope you find the enclosed useful.
RP Adam: About NEW CLP Hazard System : Incorporating Classification, Labelling & Packaging (CLP) Regulations Effective June 2015
Background &
Introduction
Most of the chemicals you might use are not dangerous if you use them properly but some
chemicals need more careful handling than others. Labels can help you identify the more
hazardous chemicals, tell you what the hazards are and how to avoid them.
Where the supplier concludes that no hazardous properties have been identified, a chemical is
not classified as hazardous and there is often nothing more to do. But where the supplier does
conclude that a chemical could cause harm, they are expected to provide information about
this on the label.
A hazard label is made up of specific symbols and warning statements that are set out in law
and chemical suppliers must use them where hazardous properties have been identified.
The following presentation from RP Adam outlines the key changes that come into force in
June 2015 with the new CLP Regulations: Chemical Hazard Information and Packaging.
RP Adam: About NEW CLP Hazard System : Incorporating Classification, Labelling & Packaging (CLP) Regulations Effective June 2015
The Real Impact:
No Cause for Alarm
It is estimated that 80-90% of professional cleaning products currently available will be
classified as hazardous in some shape or form using the new CLP calculation method.
So what options are available to the manufacturer to reduce hazard classifications?
Make the formulations weaker so that the ingredient concentrations fall below the
concentration thresholds set by the CLP Regulations.
This is likely to reduce the product performance and, arguably, supplying less concentrated
products is not environmentally responsible because we will use more and create more waste.
Alternatively, communicate the fact that the new hazard symbols should not cause alarm for
the professional user, but in fact serve as a useful reminder of proper safety practises and the
potential dangers if chemicals in general are not handled and stored properly.
Use controlled dispensing systems to reduce the risk of contact with concentrated chemicals,
because most if not all ready-to-use solutions are classified as non-hazardous.
RP Adam: About NEW CLP Hazard System : Incorporating Classification, Labelling & Packaging (CLP) Regulations Effective June 2015
Moving to CLP
Hazard System
After June 2015, all hazardous products on the market will have new CLP warning symbols or
pictograms (red diamonds) and warning messages on the label and safety data sheet.
The new CLP hazard classification system means that, in some cases, hazard pictograms will
appear on labels of existing chemical products where previously there was no hazard symbol.
This does not mean that the chemical itself is any more dangerous than it was before, it is just
a result of the way in which the new classification system is calculated.
Hazard classification is an exercise that decides what potential dangers are presented for each
chemical, what hazard symbols should appear on the label and the safety advice that must be
provided.
CLP uses different methods and criteria to classify hazards and in some cases we will see
cleaning products, which previously had no orange box hazard symbols under CHIP, having a
red diamond hazard pictogram according to CLP.
RP Adam: About NEW CLP Hazard System : Incorporating Classification, Labelling & Packaging (CLP) Regulations Effective June 2015
The NEW CLP
Hazard Pictograms
This is a not an exhaustive list but these symbols apply to RP Adam Ltd chemicals
RP Adam: About NEW CLP Hazard System : Incorporating Classification, Labelling & Packaging (CLP) Regulations Effective June 2015
Key Differences
New CLP System
Classification criteria and methods are different for some types of hazard, so some chemical
products may be classified more or less severely.
New red diamond hazard pictograms will replace orange box hazard symbols on labels.
Although many of the icons within the pictogram are similar to those used in CHIP, CLP
introduces some new icons.
The CHIP warnings, which appear under the orange hazard symbols, such as Corrosive and
Irritant are no longer used with the more generic DANGER or WARNING appearing on a new
CLP label.
New wording will appear on product labels with H (Hazard) statements and P (Precautionary)
statements replacing Risk and Safety phrases.
Expect to see more warning statements than before.
RP Adam: About NEW CLP Hazard System : Incorporating Classification, Labelling & Packaging (CLP) Regulations Effective June 2015
The NEW CLP
Hazard Pictograms
FLAMMABLE
ENVIRONMENT
DANGER
WARNING
CORROSIVE
DANGER
HARMFUL/IRRITANT
DANGER
WARNING
DANGER
RP Adam: About NEW CLP Hazard System : Incorporating Classification, Labelling & Packaging (CLP) Regulations Effective June 2015
The NEW CLP
Hazard Pictograms
The CLP Regulation introduces two new signal words: DANGER and WARNING.
If the chemical has a more severe hazard, the label includes the signal word ‘Danger’ and in
case of less severe hazards, the signal word is ‘Warning’.
DANGER:
Substances or
mixtures which cause
severe skin burns
and/or eye damage
and may be corrosive
to metals.
WARNING:
Substances or
mixtures that may
cause skin and eye
irritation or adverse
health effects.
WARNING:
Substances or mixtures
that are toxic aquatic
organisms and can cause
long term damage to
environment.
RP Adam: About NEW CLP Hazard System : Incorporating Classification, Labelling & Packaging (CLP) Regulations Effective June 2015
The NEW CLP
Hazard Pictograms
DANGER/WARNING:
Substances or
mixtures that may
catch fire if a source
of ignition is present.
WARNING:
Substances or mixtures
that may cause allergy,
asthma or breathing
difficulties when
inhaled or may be fatal
or harmful if swallowed
or if it enters airways.
DANGER/WARNING :
Substances or
mixtures which cause
or intensify fire and
explosion.
RP Adam: About NEW CLP Hazard System : Incorporating Classification, Labelling & Packaging (CLP) Regulations Effective June 2015
Treat Chemicals
With More Respect
It is always important to treat all professional cleaning products with respect. Higher
surfactant (cleaning) and biocidal active (germ killing) concentrations in these types of
professional formulations are required to get the job done in the real world.
The challenge we face is that the hazard associated with the product can be exaggerated by
the pictogram.
In some cases a product with the DANGER pictogram suggests that the liquid might burn skin
when the hazard classification indicates that it does not.
Remember that it is the RISK of harm that is the important issue here rather than just the
HAZARD symbol on the product label and the message needs to be communicated clearly.
When you see any hazard symbol, read what is actually the written on the label, read the
Safety Data Sheet and take appropriate precautions.
RP Adam: About NEW CLP Hazard System : Incorporating Classification, Labelling & Packaging (CLP) Regulations Effective June 2015
New Hazard (H)
Statements
A hazard (H) statement is a phrase that describes the nature of the hazard in the substance or
mixture. A hazard statement will be determined by the application of the classification criteria.
Examples of “H” statements include:
•
•
•
•
•
Found on the NEW product label and the
NEW CLP compliant Safety Data Sheet
Causes serious eye damage.
Causes severe burns to skin.
Toxic if swallowed.
Toxic to the aquatic life with long lasting effects.
May cause allergy or asthma symptoms or breathing difficulties if inhaled.
It replaces the ‘risk or R-phrase’ used in CHIP.
RP Adam: About NEW CLP Hazard System : Incorporating Classification, Labelling & Packaging (CLP) Regulations Effective June 2015
Precautionary
(P) Statements
A precautionary (P) statement is a phrase that describes recommended measure(s) to
minimise or prevent adverse effects resulting from exposure to a hazardous substance or
mixture due to its use or disposal.
Examples of “P” statements include:
•
•
•
•
Found on the NEW product label and the
NEW CLP compliant Safety Data Sheet
Wear eye protection.
Do not eat, drink or smoke when using this product.
Avoid release to the environment.
In case of inadequate ventilation wear respiratory protection.
Suppliers determine the appropriate precautionary statements (usually no more than six) that
are most relevant to the mandatory hazard statements and how the product is normally used.
It replaces the ‘safety or S-phrase’ used in CHIP.
RP Adam: About NEW CLP Hazard System : Incorporating Classification, Labelling & Packaging (CLP) Regulations Effective June 2015
The Most
Significant Changes
A new symbol will be introduced which identifies chemicals
that can cause very serious long term health effects.
The symbol might be used where exposure to a chemical can
cause damage to specific organs or parts of the body.
For example sensitisers that can cause allergic reactions or
substances that can cause lung damage by suffocation after
swallowing.
WARNING
RP Adam: About NEW CLP Hazard System : Incorporating Classification, Labelling & Packaging (CLP) Regulations Effective June 2015
The Most
Significant Changes
The most significant change to the new CLP rules is the use of this
pictogram: DANGER.
The use of a pictogram with an icon similar to the one used for
CORROSIVE symbol under CHIP may ring a few alarm bells with end
users of products that they have been using for years.
DANGER
Almost all surfactants used in cleaning products are classified as risk of
serious damage to eyes under the old CHIP system. Previously, a
chemical mixture would need to contain 10%+ to trigger this
classification and an orange IRRITANT symbol would be used on the
label.
Now, under CLP, only 3% surfactant is required to trigger the need for
the pictogram with the “corrosive” icon and a mere 1% is enough to add
the exclamation mark pictogram to the label.
RP Adam: About NEW CLP Hazard System : Incorporating Classification, Labelling & Packaging (CLP) Regulations Effective June 2015
The Most
Significant Changes
Note: This symbol does NOT always mean Corrosive
The same “corrosive” Danger symbol could appear on product labels,
where there is no evidence of corrosive effects to skin as CLP uses the
same symbol to show that a product has:
DANGER
• The potential to attack metal surfaces.
OR
• Causes severe damage to eyes.
RP Adam: About NEW CLP Hazard System : Incorporating Classification, Labelling & Packaging (CLP) Regulations Effective June 2015
The Most
Significant Changes
Mixture Description
Product containing 9.9% of a surfactant
CHIP
CLP
ingredient considered to be a severe eye irritant
DANGER
Product containing 3.0% of a surfactant
ingredient considered to be a severe eye irritant
No symbol
Product containing 1.0% of a surfactant
ingredient considered to be a severe eye irritant
No symbol
More ingredients are classified as hazardous to the environment. Expect
almost all concentrated disinfectant products to be classified as hazardous
to the environment. These include washroom and kitchen sanitisers and
terminal disinfectants. Remember, if diluted correctly however, ready to
use solutions are not classified as hazardous.
WARNING
RP Adam: About NEW CLP Hazard System : Incorporating Classification, Labelling & Packaging (CLP) Regulations Effective June 2015
How are NEW
Hazards Formulated
Mathematical calculations are used to predict hazard classifications as this avoids any need for
the unethical testing of chemicals on animals.
With the new CLP system, the thresholds of ingredient concentration that trigger a hazard
classification are generally lower under CHIP and this has significant implications for product
labelling.
The chemical composition of a cleaning product may remain unchanged but the hazard
classification and labelling may change quite radically.
The calculation rules used for CLP classification will result in many existing professional
cleaning products having a hazard pictogram, where previously the product would not have
been classified as hazardous and no orange symbol would be needed.
RP Adam: About NEW CLP Hazard System : Incorporating Classification, Labelling & Packaging (CLP) Regulations Effective June 2015
CHIP v CLP: Cup
of Tea Analogy
You could think about CLP and CHIP in terms of sugary tea:
Under CHIP adding 10 lumps was dangerous, adding 3 lumps might need a health warning….
But under CLP, 3 lumps is now considered Dangerous to health and 1 lump now needs a
warning!
The cup of tea is still the same as before, but the safe level for adding sugar is now lower.
Same tea, different rules!
Or
Or
RP Adam: About NEW CLP Hazard System : Incorporating Classification, Labelling & Packaging (CLP) Regulations Effective June 2015
Examples of CLP
New Labels
Copy
RP Adam: About NEW CLP Hazard System : Incorporating Classification, Labelling & Packaging (CLP) Regulations Effective June 2015
Key Action Points
with New System
Look out for new labels and supporting product information and safety data sheets.
Train employees to recognise and understand the new label information.
Check that the way you use chemical cleaning products is in accordance with advice from the
supplier.
Follow the advice provided on the new labels and in safety data sheets.
Check whether product hazard classifications have changed.
Evaluate the risks to workers and update your workplace COSHH risk assessments if necessary.
If you are an employer, communicate these changes to your employees and if you have any
questions about the new labels or safety data sheets, speak to RP Adam Ltd.
RP Adam: About NEW CLP Hazard System : Incorporating Classification, Labelling & Packaging (CLP) Regulations Effective June 2015
Implications of
NEW CLP System
The administrative burden is considerable and these changes to chemical hazard classifications
causes several issues for the professional cleaning industry manufacturer, distributor and
business consumer.
There will be a dramatic increase in the number of chemical products labelled with the
“corrosive” pictogram. This is not because they have become “more dangerous” but as a result
of a new system of classification.
There will be an increase in the requirement for and provision of PPE (Personal Protective
Equipment) for staff using professional cleaning products in response to the new symbols.
Many businesses today do not provide adequate quantities of PPE for staff; this now becomes
a top priority.
RP Adam: About NEW CLP Hazard System : Incorporating Classification, Labelling & Packaging (CLP) Regulations Effective June 2015
Are You Using
Concentrates?
Professional cleaning products are used in huge quantities every day across all types of
businesses. Manufacturers have to bring consumables costs down and be mindful of the
environmental impacts these types of products present.
Manufacturers therefore need to invest in developing chemical concentrates, essentially
getting the most out of a bottle, rather than putting less in. As long as the “hazardous”
concentrate is packaged robustly and dispensed safely, the risk to the user is minimised.
An example is a super concentrated kitchen sanitiser which may be classified in concentrate
form as follows:
But when diluted via a chemical mixing station the
ready-to-use cleaning solution carries no hazard
symbol as it is safely pre-mixed with water at
dilutions of up to 100:1.
RP Adam: About NEW CLP Hazard System : Incorporating Classification, Labelling & Packaging (CLP) Regulations Effective June 2015
Change to Safety
Data Sheets (SDS)
Safety Data Sheets (SDS) are governed by a separate set of
regulations called REACH, but where CLP brings about changes to
hazard classification, new SDS will be issued containing the new H
and P statements and hazard pictograms.
The regulations for transport are not changed by CLP and the same is
true for storage – however, as the hazard symbols are similar to
transport diamonds, it may be possible to avoid an additional
transport diamond under some circumstances.
After June 2015, new CLP compliant SDS will be available to
download from our website although there may still be CHIP
classified products available on the market from other suppliers.
RP Adam: About NEW CLP Hazard System : Incorporating Classification, Labelling & Packaging (CLP) Regulations Effective June 2015
Summary
CLP is a European Regulation that affects all chemical products made after June 2015.
CLP classification is more stringent than before, so expect all products that currently have an
orange hazard symbol to have one or more hazard diamonds.
Products previously with no hazard warnings MAY now have a CLP hazard classification.
For the next 2 years there will still be products on the market that have been classified using
the old CHIP system, so two identical chemical products sitting side by side can have different
labels (Confusion?)
The danger symbol and safety information may have changed, but this does not mean the
product in the bottle is different.
What should you do when you see products with new CLP labels? Same as before… READ THE
LABEL and for more information refer to the Safety Data Sheet.
RP Adam: About NEW CLP Hazard System : Incorporating Classification, Labelling & Packaging (CLP) Regulations Effective June 2015
Your Information
Resource Centres
Company Website: www.rpadam.co.uk
The Company Blog: www.thearpalgroupblog.com
Email: [email protected]
CLP Web Page:
http://www.rpadam.co.uk/capability/clp-regulations-chemical-hazardinformation-and-packaging/
CLP e-Book:
http://www.thearpalgroupblog.com/clp-regulations-ebook/
RP Adam: About NEW CLP Hazard System : Incorporating Classification, Labelling & Packaging (CLP) Regulations Effective June 2015