We are now reviewing our products under the new Globally Harmonised System of Classification and Labelling of Chemicals (GHS). This system was created to standardise how the hazardous properties of chemicals are classified throughout the world.
GHS is implemented in the EU via the CLP Regulation (Classification, Labelling and Packaging), where previously chemical products were regulated in the UK under CHIP.
As before, a system of calculations and thresholds is used to classify the products. This avoids the need for any unnecessary animal testing. Products containing ingredients that are over a certain threshold level are required to display the corresponding Hazard Pictogram and Statements on the label.
The orange CHIP symbols were accompanied by ‘Indication of Danger’ words, such as Toxic, Corrosive, Irritant etc but CLP will replace these with two new ‘Signal Words’. The word which appears with the pictogram will depend on the hazard class and category - severe hazards will include the word ‘DANGER’, whilst all others will include the word ‘WARNING’.
Acute toxicity, Very toxic (fatal), Toxic etc |
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Gasses under pressure |
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Harmful skin irritation, serious eye irritation |
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Flammable gasses, flammable liquids, flammable solids, flammable aerosols, organic peroxides, self-reactive, pyrophoric, self-heating, contact with water emits flammable gas |
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Explosive, self reactive, organic peroxide |
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Harmful to the environment |
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oxidising gases, oxidising liquids, oxidising solids |
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Respiratory sensitiser, mutagen, carcinogen, reproductive toxicity, systemic target organ toxicity, aspiration hazard |
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Corrosive (causes severe skin burns and eye damage), serious eye damage |
The ‘Risk (R) Phrases’ are to change to ‘Hazard (H) Statements’
H200-H299 Physical Hazard
H300-H399 Health Hazard
H400-H499 Environmental Hazard
and the ‘Safety (S) Phrases’ are to change to ‘Precautionary (P) Statements’
P100-P199 General e.g. Keep out of reach of children
P200-P299 Prevention e.g. Protect from moisture
P300-P399 Response e.g. IF ON SKIN:
P400-P499 Storage e.g. Store locked up
P500-P599 Disposal e.g. Dispose of contents/container to. . .
Some of the threshold levels in CLP are lower than under CHIP. For example under the CHIP system a product would need to contain more than 20% of an ingredient classified as R36 (Irritating to eyes) to trigger an ‘Irritant’ hazard symbol but under CLP this is reduced to 10% to trigger a hazard pictogram. This will result in many products being classified where previously they were not.
The product formulation has not changed, only the system used to classify it.
In our estimation, as many as 80% of previously non-classified products will now include a Hazard Pictogram on the label.
Interpretation of the “Corrosive” Image
As mentioned above, some threshold levels are lower under CLP than under CHIP.
This particularly affects the Hazard H318 ‘Causes serious eye damage’ (Which was R41 ‘Risk of serious damage to eyes’ under CHIP). This has changed significantly from a 10% threshold triggering an ‘Irritant’ symbol to a 3% threshold, triggering a GHS05 ‘Causes Damage’ pictogram.
The image we currently recognise as “corrosive” is and still will be used on Caustic Soda based products such as DISHWASH and OVEN CLEANER. However in the future it will ALSO be used on products which may contain only 3% of certain types of ingredients. It is now very important that users read the Hazard Statements on CLP labels rather than just relying on a glance at the image.
It is important to remember that to minimise the risks associated with a product, it should be used as recommended, which is stated on the label, Safety Data Sheets and through training.
If you use chemicals at work, you should:
1. Look out for communication regarding Classification changes on products and check that you are doing what is needed to use the chemical safely.
2. Check the Hazard and Precaution Statements that accompany the Hazard Pictogram on the label.
3. Follow the advice provided on the new labels and, where appropriate, in Safety Data Sheets and use Personal Protective Equipment (PPE) if required.
4. Review COSHH Risk Assessments and update if necessary.
5. If you are an employer, alert your employees to these changes and provide adequate information, instruction and training.