CLP (Implementation of GHS in Europe) Lars S. Rasmussen, The Wercs 2009 Global User Group June 2009 The Desmond Hotel, Albany, NY (WATER ● ENVIRONMENT ● HEALTH)

GHS world wide GHS = Globally Harmonised System UN 2002 EU, USA, Canada and transportation of dangerous goods Harmonised criteria for classification and labelling Facilitate worldwide trade Reduce animal testing

Building blocks

GHS in EU Implemented as the CLP-regulation (1272/2008) Adopted by the Council 18 November 2008 Into force 20 january 2009 Replaces Dangerous Substances Directive and Dangerous Preparations Directive 1 June 2015

Classification – Before CLP HEALTH Very Toxic Toxic Harmful Irritating Corrosive Sensitisation CMR PHYSICAL/CHEMICAL Explosive Flammable Oxidising ENVIRONMENT Acute toxicity Chronic toxicity Ozone layer Others

Classification – CLP HEALTH Acute toxicity Skin irritation Eye damage/irritation Corrosive Sensitisation CMR STOT Aspiration PHYSICAL/CHEMICAL Explosives Flammable gases Flammable liquids Flammable solids Oxidising gases Oxidising liquids Oxidising solids Flammable aerosols Gases under pressure Self-reactive substances and mixtures Pyrophoric liquids Pyrophoric solids Self-heating substances and mixtures Flammable gases in contact with water Organic peroxides Corrosive to metals ENVIRONMENT Acute toxicity Chronic toxicity Ozone layer

Global GHS vs. EU CLP Building blocks NOT implemented by the EU Building block added by EU: Hazard class, CategoryExample Flammable liquid, cat. 4Flash point F ”Combustible liquid” Acute toxicity, cat. 5LD50 (oral) mg/kg Skin irritation, cat. 3’Slightly skin irritant’ Aspiration toxicity, cat. 2’Low risk of aspiration’ Acute aquatic tox, cat. 2+3’Less than ”Very Toxic” ’ Hazard classExample Danger to the Ozone-layer’CFC-gasses’ (The old N;R59)

Hazard Pictograms

Health Physical/ chemical Environment

Hazard Statements H2xx for physical/chemical hazards –E.g. H226: Flammable liquid and vapour H3xx for health hazards –E.g. H315: Causes skin irritation H4xx for environmental hazards –E.g. H400: Very toxic to aquatic life EUHxxx for supplemental EU-phrases –E.g. EUH066: Repeated exposure may cause skin dryness or cracking

Precautionary Statements P1XX General –E.g. P102: Keep out of reach of children P2xx Prevention –E.g. P222: Do not allow contact with air P3xx Response –E.g. P314: Get medical advice/attention if you feel unwell P4xx Storage –E.g. P402: Store in a dry place P5xx Disposal –E.g. P501: Dispose of contents/container to …

Labelling Company name Address Telephone BASIC CLEANER Irritant Contains: 5% or over but less than 15%: non-ionic surfactants. Risk of serious damage to eyes. Irritating to skin. Keep out of the reach of children. In case of contact with eyes, rinse immediately with plenty of water and seek medical advice. Wear eye/face protection. If swallowed, seek medical advice immediately and show this container or label. Dispose of this material and its container to hazardous or special waste collection point.

Labelling Company name Address Telephone BASIC CLEANER Contains: Alcohols, C9-11, ethoxylated DANGER Contains: 5% or over but less than 15%: non-ionic surfactants. Causes serious eye damage. Causes skin irritation. Obtain special instructions before use. Wear protective gloves and eye protection. IF IN EYES: Rinse cautiously with water for several minutes. Remove contact lenses, if present and easy to do. Continue rinsing. Dispose of contents/container to …

Transitional provisions – Substances Either ClassificationDSD*DSD and CLPCLP LabellingDSDCLP Or ClassificationDSD and CLP CLP LabellingCLP 20 January December June 2015 *DSD = Dangerous Substance Directive 67/548/EEC Substances classified in accordance with DSD and already placed on the market before 1 December 2010 are not required to be relabelled in accordance with CLP until 1 December 2012

Transitional provisions - Mixtures Either ClassificationDPD*DPDCLP LabellingDPD CLP Or ClassificationDPD and CLP CLP LabellingCLP 20 January December June 2015 *DPD = Dangerous Preparations Directive 1999/45/EC Mixtures classified in accordance with DPD and already placed on the market before 1 June 2015 are not required to be relabelled in accordance with CLP until 1 June 2017

Translation table Substances classified before 1 December 2010 Mixtures classified before 1 June 2015 Translation table, Annex VII Translation of health and environmental hazard Translation of some physical/chemical hazards Classification under directive 67/548/EEC Physical state of the substance when relevant Classification under CLP Hazard Class-and- Category Hazard statement E;R2No direct translation possible. Fx;R12LiquidFlam. Liq. 1H224 Xn;R22Acute Tox. 4H302 Xi;R41Eye Dam. 1H318 N;R51/53Aquatic Chronic 2H411

Safety Data Sheet – Mixture before CLP

Safety Data Sheet – Mixture CLP

Safety Data Sheet – Mixture CLP after 2015

Obligations and tasks Importers, manufacturers of substances –Re-classify no later than 1 December 2010 –Re-label no later than 1 December 2010 (2012) –Notification to Classification and Labelling Inventory –Update Safety Data Sheets Formulators –Re-classify no later than 1 June 2015 –Re-label no later than 1 June 2015 (2017) –Update Safety Data Sheets End users –Adjust Work Place Instructions –Adjust company chemicals policy

What do we do now?  Define roles and obligations  Define needs for training  Define needs for update of IT-systems  Check legislation outside EU ……

Lars S. Rasmussen, (WATER ● ENVIRONMENT ● HEALTH) The Wercs 2009 Global User Group June 2009 The Desmond Hotel, Albany, NY