Sticking to CLP labelling practices

 

The new unified labelling system for mixtures, the CLP regulations, took full effect in June 2015, bringing into effect changes that massively impacted on the labelling of hazardous chemicals and pharmaceuticals.

 

As chemicals and pharmaceuticals are shipped to more countries than ever before and more people come into contact with potentially hazardous goods, the system of labelling has become increasingly complex and often dangerously misleading. 

 

Discrepancies have occurred previously where a specific chemical could be labelled toxic in one country, but not in another, while some countries had no system of classification at all.

 

In order to ensure a unified labelling system, which is understandable by all, the United Nations created the Globally Harmonised System of Classification and Labelling of Chemicals (UN GHS). CLP is the European Union’s legislation to underpin the new system, and it uses the UN GHS as its base for the classification, labelling and packaging of substances across all EU countries.

 

The aim of GHS is to create a worldwide standard for classifying chemicals globally, according to their environmental, physical and health hazards, with labels and safety data sheets universally understandable.

 

Failure to fulfil CLP requirements

Many businesses have yet to heed the warnings given out ahead of the introduction of CLP regulations, and as a result remain non-compliant, meaning they face potentially costly enforcement action. 

 

Failure to meet the requirements of CLP is a serious offence and enforcement details are left up to the national authorities to determine. Within the UK failure to comply with CLP is a criminal offence, under the Biocidal Products and Chemicals (Appointment of Authorities and Enforcement) Regulations 2013. 

 

Non-compliance can carry a fine of up to £20,000 per offence in the Magistrates Court, but can also be referred to Crown Court where fines are unlimited. Directors of businesses that fail to meet the regulations can also be held personally liable for offences committed with their consent. Directors found to have neglected their obligations to meet CLP regulations, can face the possibility of a prison sentence.

 

Many companies are aware of the consequences of non-compliance; but they may not be aware, or have lost sight of the fact, that the CLP legislation reaches beyond the initial compliance date. 

 

A lot of emphasis was placed on the 1st June 2015 deadline for compliance; however, this is in fact phase two of a three-phase roll out. Whilst all chemical mixtures that were produced after 1st June 2015 must be labelled in accordance with the new legislation, companies with mixtures already labelled, packaged and on the market have until 1st June 2017 to ensure their labels meet the updated regulations.

 

Ensuring compliance 

The new CLP regulations introduce new features to the labelling and packaging of chemicals and are extremely detailed. The size of labels, types of supplemental information and precise position of information on the label, are all covered. 

 

One key difference is that CLP implements a new pictogram system, using nine red diamond-edged hazard pictograms, which gradually move away from the familiar old orange and black square CHIP (Hazard Information and Packaging for Supply) danger symbols. There are also three new symbols: health hazard, serious health hazard, and gas under pressure.

 

Whilst correct labelling is imperative for businesses, equally important is ensuring labels remain securely in place. Every business is unique and labels can serve very different purposes. When commissioning labels, companies should consider what heat and humidity they will be expected to withstand and what their life cycle will involve. Sometimes labels with adhesives that can cope with huge shifts in temperature are required.

 

When it comes to chemical and pharmaceutical labelling there is no ‘one size fits all’ approach, so a bespoke solution, using specially supplied labels and individually adapted printing software, is often the best approach.

 

Hibiscus is a licensed provider of legal documentation to the chemical and pharmaceutical industries including dangerous goods notes, IATA forms, and standard shipping notes suitable for hand writing or laser printing. The company provides printers, software and support so that businesses can print their own labels as well as Hazchem and Kemler ADR panels and holders for transportation of hazardous materials by road. 

 

With increasingly strict enforcement action being taken against companies who fail to comply with CLP regulations, it is essential businesses act fast to ensure their labels meet the requirements. By working together with industry experts like Hibiscus compliance can be ensured and so can the safety of staff.