Implementation of CLP & GHS for PPPs - are we ready? Phil Todd: ECPA Classification and Labelling Expert Group ECPA/ECCA Crop Protection European Regulatory Conference March 2015

One off: –Transitioning labels to the new rules On going –Continuing evolution of GHS/CLP –New/updated classifications of substances from suppliers and RAC –New EU specific issues e.g. Poison Centers Are we ready now and in the future?

We must already have: –Implemented CLP labels for all substances (intermediates, active ingredients, many raw materials and co-formulants) –Relabeled any existing stocks of these substances –Updated corresponding Safety Data sheets and sent them to anyone who handles these substances By 1 st June 2015 (at the latest) –Implement CLP labels for all newly produced products (mixtures) –Update corresponding Safety Data Sheets updated and send them to customers –Plan to consume or relabel existing stocks by 1 st June 2017 Transition to CLP: What we have to achieve

Are we ready now?

Mixture reclassification status Registration authorities approach Enlightened An industry responsibility: “Get on with it” E.g. UK CRDUK CRD Consistent with ECPA view Pragmatic Initially required notification and approval before relabelling Available resource not adequate Changed to selective review “after the event” e.g. Belgium Unrealistic Notification and approval required before relabelling Inadequate resources and processes Complicated by incorrect understanding of requirements Conflict between EU and national law

Action for companies Registration authorities approach Enlightened Make sure that we deliver Pragmatic Make sure that we deliver Challenge any incorrect reviews Unrealistic Highlight the impossible position that companies will be in If nothing changes, ensure that we comply with CLP (in an open and transparent way)

Constant engagement with Commission –1 data set + 1 rule ≠ 1 classification –Highlighting process issues Commission does not recognize the problem We need concrete examples of –Classifications from authorities that do not follow CLP –National processes that prevent compliance with CLP What ECPA is doing How you can help

Watch-outs for industry Do not expect classifications and labels to be consistent between products and countries “Similar” products can legitimately vary Registration authority “peculiarities” act against harmonization Consistency Physically changing labels is not a “5 minute job” Defining the classification on paper is not the end of the process Timing CLP and transport classifications should be consistent Manufacturing and Storage facilities affected via Seveso directive Downstream impacts In a typical supply chain, there are multiple “placing on the market” CLP obligations start with the first “placing on the market” and not the last “Placing on the market” We can expect systematic enforcement, often triggered by REACH projects Enforcement often led by non-agricultural ministries Enforcement often “tick box” approach Enforcement

Are we ready for the future?

CLP continues to evolve New/amended hazard criteria We’ve already had Skin sensitization subcategories Ozone depleting substances Chronic aquatic toxicity On the way Unstable explosives Pyrophoric gases Combustible dusts? ……… We need to review our classifications every time that criteria are added or changed

CLP continues to evolve Updates to P and H statements We’ve already had Numerous changes to P statements P281, P285 deleted Numerous changes to wording “Remove victim”  “Remove person” (P304 + P340) ………. On the way Fortunately none in GHS Rev.6 Expect more in GHS Rev.7 Standing working group at UN Even if classifications don’t change, need to constantly review labels There is now a structure that encourages constant change

Substance classifications change A classification factory 50 classifications per year 1 ATP per year  Every classification change has to be implemented for substance and relevant mixtures RAC Deadlines + continuous process New data miraculously being found Reevaluation of old data Limited generation of new data  Substance self classifications changing  Every classification has to be implemented for substance and relevant mixtures REACH

Harmonised (at the upper level) information submission requirements Less likely to harmonize submission methods Unique Formulation Identifier (UFI) on every label EU specifics: Poison Centers

Closing thought Classification and Labelling has moved from a project approach to a continuous process approach. Have we also changed our approach?

Thank You