Report on Communication of Chemical Hazards presentation made to Ireland Branch North West District on 19 May

3 June 2010

Nigel Ashcroft, the outgoing Chair of the District, gave an interesting and informed presentation covering the new Classification, Labelling and Packaging Regulations (CLP) due to take effect in December 2010. Although he was addressing an audience of experienced health and safety professionals he approached the subject in a systematic way. For clarity he proceeded from a position that the audience had little or no prior knowledge of chemicals in the workplace.

Chemicals Users
The Seminar was publicised to attract anyone who uses: diesels, oils, cleaners, cement, paint, pesticides, ink cartridges etc.  That meant that it applied to anyone using any kind of chemicals or substances in the workplace.  The Seminar was not designed to deal with the REACH requirements applicable to chemical manufacturers.

Nigel began by asking why is chemical hazard communication important?  He went on to outline how those using chemicals need to know what they are handling and the precautions to take. He reminded the audience that others also need to know and they include fellow workers, cleaners, maintenance personnel, visitors and the Emergency Services.

New CLP System/move to GHS
He then explained the new Classification, Labelling and Packaging (CLP) system that is due to take effect in Ireland in December 2010.  He clarified the move to have one coherent system for all chemicals in the EU and the reasoning behind the adoption of Globally Harmonised System of Classification (GHS).  He also mentioned REACH and Safety Data Sheets.

Safety Data Sheets (SDS)
He focused on the importance of Safety Data Sheets (SDS) as key information sources for Downstream Users who have obligations to identify, apply and recommend appropriate measures to adequately control risks identified in the SDS, check the document when it is received, check that it is in a language that is understood, that the organisation’s use of the substance is covered by it, that the information is consistent with classification, label etc., that the risk management measures are appropriate and the relevant exposure scenario is attached.  If any of this information is incorrect then there is an obligation on the Downstream User to contact the supplier.

Assuming that SDS is correct it will allow the user to evaluate risks to workers, to make SDS information available to workers and records of chemicals used etc. should be kept for 10 years

Main changes to Safety Data Sheets
Nigel went on to explain that the familiar SDS will change.  The main changes will be:
 More detailed structure with more sub-sections
 Increased content - probably longer
 More targeted information & Exposure Scenario
 Updated regularly
 Dual classifications until 2015
 New Annex II from December 2010

Key steps in CLP
In his coverage of CLP he outlined the key steps in the process which include Classification, labelling, packaging and notification to C&L Inventory.  He went through the CLP Classifications which are, in brief:
 Physical: Oxidising, Explosive, Flammable, Gases
 Human Health: Corrosive, Toxic, “Harmful”, Carcinogens etc.
 Environment
 Mixtures, e.g. Paint mixtures, which may contain one or more hazardous chemicals, must be self-classified and labelled accordingly.

Nigel gave comprehensive advice for those organisations dealing with chemicals on how to prepare for CLP which included the following steps:
 Identify your Roles and Obligations
 Create an Inventory of all Substances & Mixtures
 Ensure Expertise - in-house or Consultant
 Check all Substances’ Identities
 Gather all Information
 Examine, Evaluate

And he informed the group that the database is being established and maintained by ECHA and will be on the ECHA website in 2011.

New Hazard and Precautionary Statements
He clarified that the existing Risk and Safety Phrases will be replaced under the new system by Hazard Statements and Precautionary Statements which are somewhat different.   He also covered CLP Labelling and Packaging briefly and explained the use of new pictograms, moving away from the familiar orange / black label to a white diamond with red outline, with a black symbol inside it.  Some symbols will be very similar to our existing system with one or two new ones, e.g. compressed gas symbol and “harmful” (exploding person) symbol.

Chemical Risk Assessment
Nigel also emphasised that when undertaking a chemical risk assessment, the information on the Label and in the SDS must be considered.

Overall it was a comprehensive whistle-stop tour of CLP, SDS and associated topics. The audience listened attentively and his presentation was followed by a short lively question and answer session.

Mary Darlington, CFIOSH