Chemical Labels Guide en
Chemical Labels Guide en
Chemical Labels Guide en
Social Europe
This publication is supported by the European Union programme for employment and social solidarity – Progress (2007–13).
This programme is implemented by the European Commission. It was established to financially support the implementation of
the objectives of the European Union in the employment, social affairs and equal opportunities area, and thereby contribute to
the achievement of the Europe 2020 strategy goals in these fields.
The 7-year programme targets all stakeholders who can help shape the development of appropriate and effective
employment and social legislation and policies, across the EU-27, EFTA–EEA and EU candidate and pre-candidate countries.
European Commission
Directorate-General for Employment, Social Affairs and Inclusion
Unit B3
ISBN: 978-92-79-28347-5
doi:10.2767/9499
Printed in Italy
1. Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
3. Changes to labels . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
3.1. New pictograms . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
3.2. Signal word . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
3.3. Hazard (H) statements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
3.4. Precautionary (P) statements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
3.5. Supplementary labelling section . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
3.6. Combined transport and supply labelling . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
3.7. Example labels . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
7. Appendices . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45
7.1. Appendix 1 – Sources of further information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .45
7.2. Appendix 2 – Glossary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 48
1. Introduction
This document is intended to provide practical causing adverse effects to the health of people
guidance to employers and workers on how the or to the environment.
directly acting CLP regulation ((EC) No 1272/2008
on the classification, labelling and packaging of One of the key steps in identifying hazardous
substances and mixtures) will affect the following chemical substances and mixtures is to review
worker protection directives: the information about them provided by suppli-
ers in the form of labels and safety data sheets.
‣‣ chemical agents directive (98/24/EC); For many years, the dangerous substances
directive (67/548/EEC) (DSD) and the dangerous
‣‣ carcinogens and mutagens directive preparations directive (1999/45/EC) (DPD) have
(2004/37/EC); required that suppliers of chemical substances
and mixtures:
‣‣ safety signs directive (92/58/EEC);
‣‣ identify the hazards of the chemical using a
‣‣ pregnant workers directive (92/85/EEC); standardised set of classification criteria;
5
Chemicals at work – a new labelling system
CLP adopts the UN Globally Harmonised System and in the warning symbols, hazard information
of Classification and Labelling of Chemicals (GHS) and safety advice to be included on the label and
within the EU. The GHS aims to improve worker other documents.
safety throughout the world by introducing a com-
mon set of hazard criteria and labelling elements These changes mean that you will need to take
to be used for chemicals. The GHS has the same action to make sure that you and your employees
basic aims as the DSD and DPD; that is to ensure recognise and understand the new label informa-
that chemical suppliers identify the hazards of tion. In cases where new data have been gener-
their products, package them safely and com- ated or made available under REACH which change
municate information about the hazards through the classification of the substance or mixture, it
labels and other documents. However, there are may also be necessary to review and update your
some differences between the GHS (and thus risk assessments and your procedures.
CLP and the SDS provisions of REACH) and the
system set out in the DSD and DPD. In particular Detailed guidance on CLP has been produced by
there are some differences in the classification the European Chemicals Agency (ECHA). Further
criteria used to identify a substance or mixture information and links to relevant documents are
as ‘hazardous’ (‘dangerous’ under the DSD/DPD), given in Appendix 1 to this guide.
6
2. What is CLP and how
will it affect me?
CLP is changing the classification system for change their products over to the new system.
identifying and describing chemical hazards in Some products have already been moved over
Europe, and the way this information about the to the new system, and the rest will need to
hazards of chemicals is communicated on labels be changed over by 1 June 2015, although
and in safety data sheets and other documents. some stocks of products already in the supply
chain may be onward supplied without need-
CLP is being introduced gradually over a ing to be relabelled for a further 2 years after
number of years to allow suppliers time to the deadline.
Substances All substances must be classified and All substances classified and labelled to CLP.
labelled according to CLP. Both CLP and DSD Only CLP classifications need appear on the SDS.
classifications must appear on the SDS.
2-year derogation, to
allow stocks already
on the market to be
onward supplied.
Mixtures May be classified and labelled according to All mixtures classified and labelled to CLP. Only
either DPD or CLP. CLP classifications need appear on the SDS.
If labelled according to CLP, both DPD and CLP
classifications must appear on the SDS.
2-year derogation to
allow stocks already
on the market to be
onward supplied.
This means that over the next few years you are referred to as the ‘purple book’ because of its cover.
likely to receive, and have stocks of, chemical sub- The GHS has been developed as a result of initia-
stances and mixtures labelled according to both tives at the 1992 United Nations Conference on
systems, the DSD/DPD and CLP, and you and your Environment and Development to improve worker
employees will need to be trained to recognise protection around the world by introducing a com-
and understand both types of label information. mon set of hazard criteria and labelling elements to
It is also important that you help your customers be used for chemicals. It is managed and published
understand the new classification system. by the UNECE, with input from many intergovern-
mental organisations and national experts, and is
updated every 2 years. The GHS is being adopted by
2.1. Why has CLP been many countries around the world and is also used
introduced? as the basis for international and national transport
regulations for dangerous goods including the UN
CLP adopts the Globally Harmonised System of Recommendations on the Transport of Dangerous
Classification and Labelling of Chemicals, more Goods – Model regulations (commonly referred to
commonly known as the GHS, and sometimes as the ‘orange book’).
7
Chemicals at work – a new labelling system
GHS
UN recommendations EU CPL
on TDG
EU inland
transport directive
2.2. How will CLP changes into numbered divisions or categories, with the
affect the substances lowest numbers representing the most severe
and mixtures I use? hazards. In some cases, hazard statements may
be used for two or more hazard categories. Under
There are some differences in the hazard clas- CLP the criteria for determining whether a sub-
sification system used in the GHS, and there- stance or mixture is classified as hazardous may
fore CLP, compared to the previous classification be different. There are also some new hazard
system, which was set out in the dangerous classes. This means that some of the chemical
substances directive (DSD) and the dangerous substances and mixtures that you are familiar
preparations directive (DPD). Under the DSD/ with may change classification, or become clas-
DPD system, dangerous substances and mix- sified as hazardous for the first time.
tures are allocated to 15 hazards classes and
their associated risk phrases. Under CLP, hazard- CLP has also introduced some termin
ology
ous substances and mixtures are allocated to changes that you should be aware of, as
28 hazard classes, which are further subdivided shown below.
8
At the same time, REACH is also having for existing chemicals, and therefore more
an impact on the classification of some changes to classifications.
chemicals, as it requires manufacturers and
importers to undertake a more thorough If you find that the classification of the products
assessment of available hazard data for you use has changed, you may need to review
substances and, where necessary, to carry your risk assessments and safe working practices
out additional testing to fill data gaps. This to make sure that you can continue to use these
may result in new hazards being identified substances and mixtures safely.
Key points
‣‣ Look out for new labels and safety data sheets.
‣‣ Train employees to understand and recognise the new label information.
‣‣ Check that your use of the substance or mixture is covered on the safety data sheet and is
not advised against.
‣‣ Follow the advice provided on the new labels and in safety data sheets.
‣‣ Check whether the classification has changed.
‣‣ Evaluate the risks to workers and update your workplace risk assessments if necessary.
‣‣ If you are an employer, communicate these changes to your employees.
‣‣ If you have any questions about the new label or safety data sheet, speak to your supplier.
If the classification of a substance or mixture available will be reflected in the DSD/DPD system
changes, it is important that you understand classification as well as in the new CLP system.
the reason for this, as it may impact on the
risk management measures that you choose. Because CLP will change the classifications of
Classifications may change for several reasons. some substances and mixtures, and because
REACH and CLP are identifying new hazard infor-
‣‣ The hazard data are still the same, but mation about some substances, it is expected that
CLP classification criteria result in a some suppliers will reformulate some of their prod-
different classification. ucts to avoid the products being placed in a more
severe hazard class and/or category. You should
‣‣ New hazard information has been identified, look out for, and ask your suppliers to alert you to,
e.g. through REACH and the substance any changes as they may mean that you need to
or mixture is more/less hazardous than change some of your risk management measures.
previously thought. For example a change of solvent in a mixture may
mean that the gloves you use no longer provide
‣‣ A mixture has been reformulated with adequate protection and a different glove mate-
different component substances that have rial may be needed, or the equipment you use to
different hazards. monitor airborne concentrations of the solvent may
need to be adjusted to measure the new solvent.
Until at least 1 June 2015 suppliers will have to
provide classifications under the old DSD/DPD and If you are not sure why the classification of a
the CLP system in the SDS, so any fundamental substance or mixture has changed, you should
change of classification from new information contact your supplier for more information.
9
Chemicals at work – a new labelling system
3. Changes to labels
Suppliers of hazardous substances and mixtures During the transitional period, labels should only
have, for many years, been required by the DSD include information from one system, and the
and DPD to label their products with a stand- package should be labelled according to either
ard set of information to alert their customers to the DSD/DPD or CLP. Packages should not include
the dangers of the substance or mixture so that both sets of labels.
they can take actions to manage them safely and
reduce risks in the workplace. Remember that mandated labels are only needed
for substances and mixtures classified as haz-
CLP has not changed the purpose of the label, but ardous, and for mixtures that are not otherwise
the meaning of several of the symbols has changed, classified as hazardous but contain hazardous
and CLP has made a number of changes to the component substances above thresholds of con-
details of the information to be provided, including: cern. For products not classified as hazardous
or not containing hazardous component sub-
‣‣ new red-framed pictograms to replace the stances, there is no formal requirement for spe-
familiar orange danger symbols; cific labelling.
‣‣ a signal word instead of indications of danger; Until 1 June 2015 suppliers will have to pro-
vide classifications under the old DSD/DPD and
‣‣ hazard statements instead of risk phrases; the CLP system in their SDSs, so you can still
carry out your risk assessments the current way
‣‣ precautionary statements instead of until switching over to new schemes that will
safety phrases; be developed.
Other requirements, such as the requirement to Under CLP, the seven familiar orange squares
show names and identifiers for hazardous sub- with symbols will be replaced by nine new red-
stances or the hazardous component substances bordered diamond symbols. Six of these new sym-
in a mixture, the name, address and telephone bols are very similar, but, as seen below, there
number of the supplier, and the nominal quantity are three new or changed ones to become
of the package, are largely unchanged. familiar with.
10
Figure 2: The seven familiar DSD/DPD symbols The nine GHS pictograms
Contains gases under pressure No symbol under the DSD and DPD
11
Chemicals at work – a new labelling system
12
Label elements under the DSD and DPD Label elements under CLP
Symbols Pictograms
NB: On single packagings, pictograms may
be omitted if they repeat transport hazard
class labels
Indications of danger (or occasionally nothing) Signal words ‘Danger’ or ‘Warning’ (or
occasionally nothing)
Risk (R) phrases Hazard (H) statements
Safety (S) phrases Precautionary (P) statements
Some risk phrases Supplementary labelling information
Special labelling phrases for certain
preparations
Other regulatory information
Supplementary information
NB: The classification information shown in the above example is the harmonised classification for the substance as
given in Annex VI to the CLP regulation ((EC) No 1272/2008) and was correct at the time this document was prepared
(1 December 2011).
13
Chemicals at work – a new labelling system
Trade name
SuperClean
Pictograms
Use instructions
Apply to surfaces
using a damp cloth
Signal word
Warning
Causes serious eye irritation.
1 2 3 4 5 6
Keep out of reach of children.
Wear protective gloves / face protection.
Hazard and IF IN EYES: Rinse cautiously with water for
precautionary several minutes. Remove contact lenses, if
present and easy to do. Continue rinsing.
statements
Contains Anionic surfactant <5%
14
Example 3: Combined supply and transport label
Proper shipping
name and UN number
Methanol UN1230
Transport
labels
NB: The classification information shown in the above example is the harmonised classification for the substance as given
in Annex VI to the CLP regulation ((EC) No 1272/2008) and in the ADR Agreement 2011 and was correct at the time this
document was prepared (1 December 2011).
15
Chemicals at work – a new labelling system
4. Practical considerations
for the workplace
Minimum health and safety requirements for the the risk from a hazardous chemical agent to
protection of workers from hazardous chemical the safety and health of workers at work is
substances and their mixtures are set out in five eliminated or reduced to a minimum. Employers
European directives: have a number of duties under this direc-
tive, including:
‣‣ chemical agents directive (98/24/EC);
‣‣ identification of hazardous chemicals;
‣‣ carcinogens and mutagens directive
(2004/37/EC); ‣‣ substitution of hazardous chemicals with
less hazardous alternatives;
‣‣ safety signs directive (92/58/EEC);
‣‣ risk assessment to determine if the level,
‣‣ pregnant workers directive (92/85/EEC); type and duration of exposure is acceptable;
‣‣ young people at work directive (94/33/EC). ‣‣ safe use, handling, storing and transporting
of substances;
These directives have been implemented in
the national legislation of each Member State. ‣‣ emergency plans and procedures;
Information on national legislation and general
guidance on how to comply will be available from ‣‣ information, instruction, training and
the authorities responsible for occupational health supervision for employees;
and safety in each Member State. This section
provides more information about each of these ‣‣ monitoring and health surveillance;
directives, and how the change from the DSD/DPD
to CLP may affect the things you do. ‣‣ record keeping;
16
Key activities affected by change to CLP Tips for transition to CLP
Identify hazardous chemical agents Check labels and SDSs carefully to make sure all hazards are identified
and understood.
‣‣ Has the classification of the substance or mixture changed to a more
or less severe hazard class and category?
‣‣ Are there any additional hazard statements in the supplementary
section of the label?
‣‣ Check both transport labels and supply pictograms for
single containers.
Risk assessment and introduction of appropriate Follow safety information on the label and the SDS.
risk management measures to eliminate/
‣‣ If an extended SDS (ext-SDS) with exposure scenario has been
minimise risks
provided, ensure you work within any limitations set in this document.
‣‣ If classifications have changed, consider if and how this affects your
risk assessment and any control banding systems you use.
‣‣ If the safety advice on the label or in the SDS has changed, do you
need to change your procedures to take account of this advice?
Safe use, handling, storing and transporting Check whether the classification has changed – does this affect where
of substances you store the chemical, how you use and handle it, and how it needs to
be transported?
Emergency plans and procedures Check consistency with safety information on the label and the SDS.
Information, instruction, training and supervision Train employees to make sure they understand the new label information.
for employees
Health monitoring and record keeping Check whether substances are used for which regular monitoring is
required and adapt record keeping.
Example 1
Company X purchases a substance which was labelled under the DSD as
Irritant
R41 Risk of serious damage to eyes.
They are concerned because the new CLP label now carries the corrosive pictogram
Danger
H318 Causes serious eye damage.
Company X is worried it will have to change its procedures as a result.
The classification criteria for substances and mixtures which cause serious eye irritation are very similar between the DSD
and CLP, and the intrinsic hazard of the substance is still the same, although the labels are different. If Company X has
properly identified the risks from using the substance and has put in place suitable procedures and control measures to
manage the risk, then Company X can reasonably conclude that these measures should still be sufficient to manage the
risk with the new CLP labels, and no changes to the existing procedures and control measures are needed.
17
Chemicals at work – a new labelling system
18
4.3. Safety signs relation to hazardous chemical substances and
directive (92/58/EEC) mixtures include the following.
The safety signs directive implements a sys- ‣‣ Ensuring that containers and visible pipes for
tem of harmonised signs across Europe so that storage or transport of dangerous substances or
non-native language workers have the same mixtures are labelled with pictograms or warning
protection as native language workers without signs, and also with the name of the substance
needing to understand the information given in and details of the hazard where appropriate.
a particular language. The directive is concerned Storage compounds holding significant quantities
with health and safety signs at work relating of dangerous substances or mixtures must be
to location and identification of containers and marked with suitable warning signs.
pipes, fire-fighting equipment, certain traffic
routes and illuminated and acoustic signs, as ‣‣ Giving information to employees on what
well as the introduction of appropriate verbal measures they should take in connection
communications and hand signals, amongst with safety signs and suitable training on the
other information. The duties of employers in meaning of safety signs.
19
Chemicals at work – a new labelling system
20
4.5. Young people at work exposure to dangerous substances, such as work
directive (94/33/EC) involving harmful exposure to agents which pre-
sent a chronic health risk.
The young workers directive (YWD) prevents
young people being employed for work which The risk assessment under this directive must
exceeds the mental or physical capacities of consider effects on the safety, physical and men-
young people or for work involving harmful tal health and development of young people.
Example 2
Company Y uses a substance which was not classified under the DSD. However, under CLP the product is classified for
chronic toxicity effects, due to the changes in the classification criteria for this effect, and is labelled
Warning
H373 May cause damage to organs (kidneys) through prolonged or repeated exposure.
Company Y should review how it uses this substance and decide what control measures it may need to put in place to
make sure it employees are adequately protected. In particular, it should review whether vulnerable workers, such as
young people, are affected.
21
Chemicals at work – a new labelling system
CLP, like the DSD and DPD, aims to identify haz- names, e.g. ‘Flam. Liq. 2’ is used as a short code
ardous properties of chemical substances and mix- for Flammable Liquid Category 2. These short
tures so that users can undertake a risk assessment codes are not normally used on their own, but
appropriate to how they use the substance or mix- should be used with the H statement number to
ture. Hazards are generally grouped into three types: provide a complete description of the type of haz-
ard presented, e.g. ‘Flam. Liq. 2, H225’.
‣‣ physical hazards that may cause harm to
workers through their ability to explode, burn The classes are also referred to in REACH by a
or react with other chemicals in a dangerous class numbering, where the class number is the
way which threatens the physical safety of section reference in CLP Annex I for that haz-
the worker; ard class, e.g. flammable liquids are ‘Class 2.6’.
Take care if using these class numbers not to
‣‣ health hazards that may have harmful confuse them with the Transport of Dangerous
effects on the health of workers either in Goods (TDG) class numbering system, which
the short term (acute hazards) or in the long is different.
term (chronic hazards);
22
5.1.1. Explosives explosives are grouped into seven categories,
which are the same as those used for the trans-
Explosive substances, mixtures and articles were port of dangerous goods and take into considera-
grouped into two categories under the DSD/ tion both the intrinsic properties of the substance,
DPD, based on their intrinsic properties. In CLP, mixture or article, and also its packaging.
5.1.2. Flammable gases their own hazard class. Overall, this hazard class
covers the same substances and mixtures as classi-
Flammable gases were all identified as ‘Extremely fied under the DSD/DPD but, in CLP, the hazard class
flammable’ under the DSD/DPD. In CLP, they are given is split into two categories with different labelling.
Danger
Extremely flammable — Flammable Gas H221: Flammable gas
Category 2
Warning
23
Chemicals at work – a new labelling system
Danger
Extremely flammable R11: Highly Flammable H223: Flammable aerosol
or flammable aerosol
Category 2
Highly flammable
— R10: Flammable
Warning
Flammable
5.1.4. Oxidising gases by providing their own oxygen in a fire. The tests
used to identify these substances and mixtures
Oxidisers are substances and mixtures which can are the same in both systems and the same sub-
increase the fire hazard of combustible materials stances and mixtures will be classified and labelled.
Oxidising Danger
24
5.1.5. Gases under pressure packaged and not the intrinsic hazard of the gaseous
substance or mixture per se. This hazard category is
Gases under pressure is a new category under CLP assigned to all commercial gases which are further
and this aspect was not previously addressed under classified into four groups: compressed gas; lique-
the DSD/DPD since it is based upon how the gas is fied gas; refrigerated liquefied gas; or dissolved gas.
5.1.6. Flammable liquids similar, but the cut-off points between the three
categories have changed slightly, so that a few
Under the DSD/DPD, flammable liquids were clas- more substances and mixtures will be classified
sified as extremely flammable, highly flammable as flammable liquids, and some substances and
or flammable, depending on their flashpoint and mixtures which were classified before will be clas-
initial boiling point. CLP classification is very sified in a higher category.
25
Chemicals at work – a new labelling system
5.1.7. Flammable solids CLP they are split into two categories depending
on whether a wetted zone in the test substance
This hazard class covers solids which are readily or mixture is able to stop the fire or not. For metal
ignited. The hazard classification criteria for CLP powders, classification is based upon the speed at
are based on a similar test to the DSD/DPD but in which a pile of the test material burns.
Danger
Flammable solid
Category 2
Highly flammable
Warning
26
5.1.8. Self-reactive substances R3) or as extremely/highly/flammable or, in some
and mixtures cases, may not have been classified as hazardous.
Under CLP, self-reactive substances and mixtures
Self-reactive substances are unstable substances are given their own hazard class and are divided
which may decompose and become hot causing into seven categories depending on their proper-
fire or explosion, even without the presence of ties, the same as in the transport regulations. Like
air. Under the DSD/DPD, self-reactive substances explosives, the test procedure is not only depend-
and mixtures do not have their own hazard class ent on the intrinsic hazards of the substance or
but are classified either as explosive (E; R2 or mixture, but is also package dependent.
DSD/DPD symbol, Risk phrases CLP pictogram and Hazard class and Hazard statement
indication of danger signal word category
Self-reactive
H242: Heating may cause
substances
R11: Highly a fire
Types C & D
flammable
Danger
Highly flammable
Self-reactive
H242: Heating may cause
substances
a fire
Types E & F
R10: Flammable Warning
Self-reactive
— substances —
Not classified Type G
27
Chemicals at work – a new labelling system
Danger
Highly flammable Self-heating H252: Self-heating in large
Category 2 quantities: may catch fire
— —
Warning
28
5.1.11. Substances and mixtures quantities. The classification criteria and proce-
which, in contact with water, dures are very similar in both CLP and the DSD/
emit flammable gases DPD; however, in CLP they are subdivided into
three categories.
These substances and mixtures react with water
and may release flammable gases in hazardous
Warning
29
Chemicals at work – a new labelling system
5.1.12. Oxidising liquids by providing their own oxygen in a fire. The clas-
and oxidising solids sification criteria and procedures are very simi-
lar in both CLP and the DSD/DPD; however, the
Oxidisers are substances and mixtures which can way they are subdivided is different between the
increase the fire hazard of combustible materials two systems.
30
5.1.13. Organic peroxides under each system. Under the DSD/DPD, organic per-
oxides were identified either as explosive (E; R2 or R3)
Under both CLP and the DSD/DPD the identification of or oxidising (O; R7). Under CLP, organic peroxides are
organic peroxides is based on chemical structure (i.e. given their own hazard class and divided into seven
substances with an –O–O– bond) and, consequently, categories depending on their intrinsic properties, and
the same substances and mixtures are identified also on how they are packaged.
Danger
R7: May cause fire Organic peroxide H242: Heating may cause
Types C & D a fire
Danger
Organic peroxide H242: Heating may cause
Types E & F a fire
Oxidising
Warning
Organic peroxide
— Type G —
31
Chemicals at work – a new labelling system
5.1.14. Corrosive to metals and mixtures which can corrode steel or alumin-
ium faster than a set rate. Some chemical users
Corrosive to metals is a new hazard category may be familiar with this hazard as it is also used
introduced under CLP. It is used for substances for transport of dangerous goods regulations.
Warning
5.1.15. Other physical hazards part of the GHS. These additional hazards
and risk phrases have been included in CLP
The DSD and DPD include a number of risk unchanged except for the numbering of
phrases for other hazards which are not the phrases.
32
5.2. Health hazards in contact with skin (dermal exposure) or
through inhalation.
5.2.1. Acute toxicity
CLP does not change the overall scope of classification
Acutely toxic substances and mixtures may for acute toxicity but there are important differences in
cause harm to workers' health after either a the dose ranges used to sub-divide this hazard class
single exposure or several exposures over a between the two systems. This means that some sub-
short period of time (a few hours). They may stances and mixtures may move into a higher hazard
cause these affects by ingestion (oral exposure), category in CLP compared to the DSD/DPD.
Note that the same hazard statement is used you undue concern, as in reality this information
for both Category 1 and Category 2 acutely toxic was not known under the previous DPD system
substances and mixtures. You will not be able to either – this is simply better communication of
determine which of these hazard categories applies existing information.
to your substance or mixture from the label, and
you will need to refer to the SDS to identify this if Note that the GHS includes Acute Tox 5 for sub-
it is important for your risk management system. stances with an acute toxic effect (ATE) level of
2 000–5 000 mg/kg. In Europe, the maximum dose
CLP includes specific provisions for dealing with indicated for animal testing is 2 000 mg/kg, the
mixtures where toxicity data is not available for all use of doses of up to 5 000 mg/kg is discouraged
of the components, and you may see the phrase for welfare reasons. Some international labels
‘contains x % of ingredients of unknown toxic- may include Category 5 (note that this does not
ity’ appearing on labels. This should not cause carry a pictogram).
33
Chemicals at work – a new labelling system
5.2.2. Skin corrosion and irritation Note that the same H statement is used for all three
skin corrosion categories (1A/1B/1C). Therefore you
Corrosive substances and mixtures can cause will need to refer to the SDS if it is important for your
serious damage and burns to the skin which control measures to identify the hazard category.
can take time to heal and may leave perma-
nent damage such as scarring. Irritant sub- The generic concentration limits used to calculate
stances and mixtures may cause redness, the classification of mixtures containing corrosive
inflammation, etc. of the skin, but this gener- and irritant substances under CLP have decreased
ally heals within a short period of time. There significantly when compared with those for the
is a good correlation between the DSD/DPD DPD. It is expected that many more mixtures will
and CLP classification criteria for corrosivity be classified as ‘corrosive’ and/or ‘irritant’ under
and irritation. this regulation compared to the DPD.
Irritant Warning
34
5.2.3. Eye damage and irritation The generic concentration limits used to calcu-
late the classification of mixtures containing
Like corrosive substances and mixtures, substances these substances under CLP have decreased
and mixtures classified as causing eye damage are significantly when compared with those for the
capable of causing serious and permanent effects. DPD. It is expected that many more mixtures
Irritant substances and mixtures may cause effects will be classified as ‘serious eye irritants’ and
that heal with a relatively short period of time. ‘eye irritants’.
Danger
R36: Irritating to Eye irritation H319: Causes serious eye
eyes Category 2 irritation
Irritant
Warning
5.2.4. Sensitisers
Sensitisers are substances which, after an initial as asthma (respiratory sensitisers) or an allergic
exposure, may provoke an allergic reaction such skin reaction (skin sensitisers).
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Chemicals at work – a new labelling system
5.2.5. Germ cell mutagenicity changes in the germ cells, i.e. the sperm and egg cells,
which can be passed on to the next generation. The
Germ cell mutagens are substances and mixtures classification criteria for substances and mixtures are
which may cause heritable genetic damage by causing very similar in both the DSD/DPD and CLP.
Note that both the DSD/DPD and CLP systems which system is being used if you are sup-
use the term ‘Category 2’ but to mean differ- plied with substances or mixtures described as
ent things. You should therefore check carefully Category 2 mutagens.
36
5.2.6. Carcinogenicity Note that both the DSD/DPD and CLP systems use
the term ‘Category 2’ but to mean different things.
Carcinogens are substances that may cause cancer. You should therefore check carefully which system
The classification criteria for substances and mix- is being used if you are supplied with substances
tures are very similar between the DSD/DPD and CLP. or mixtures described as Category 2 carcinogens.
5.2.7. Reproductive toxicity Note that both the DSD/DPD and CLP systems use
the term ‘Category 2’ but to mean different things.
Reproductive toxins are substances and mixtures which You should therefore check carefully which system
may cause adverse effects on fertility or on develop- is being used if you are supplied with substances
ment. The classification criteria for substances and mix- or mixtures described as Category 2 reproduc-
tures are very similar between the DSD/DPD and CLP. tive toxins.
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Chemicals at work – a new labelling system
5.2.8. Specific target organ more general toxicity. STOT effects may hap-
toxicity (STOT) pen after a single exposure, or after several
repeated exposures.
Specific target organ toxicity is the ability
of the substance or mixture to cause harm Specific target organ toxicity – single expo-
to particular organs of the body, such as sure (SE): the classification criteria for sub-
the blood, the liver or the nervous system, stances and mixtures are very similar in both
at doses below those which would cause the DSD/DPD and CLP.
38
Specific target organ toxicity – repeated exposure CLP are likely to result in a few more substances
(RE): although similar, the classification criteria for and mixtures being classified for this effect.
Harmful Danger
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Chemicals at work – a new labelling system
5.2.10. Other health hazards One possible change that may be noted by users is
that these additional EUH hazard statements will
The DSD and DPD include a number of risk now be placed in a supplementary section of the
phrases for other hazards which are not part label rather than in the main body of the hazard
of the GHS. These additional hazards and risk and precautionary statements.
phrases have been included in CLP unchanged
except for the numbering of the phrases.
40
Note that Aquatic Acute 2 and 3 are not being to the old DSD R51 and R52 and indicate
used in CLP, even though they are described that even though there is toxicity to aquatic
under GHS. Therefore, it is possible that organisms, the substance or components of a
imported chemicals with GHS labels will include mixture will biodegrade rapidly to ensure no
these criteria. Acute 2 and 3 are equivalent long-term effects.
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Chemicals at work – a new labelling system
42
SDS section Key changes
Section 4 Section 4.2 – As well as first aid measures, this section of the SDS will now
First aid measures include information about the likely symptoms and effects of exposure, both
acute and delayed.
Section 5 No significant changes likely unless new information about the hazards
Firefighting measures of the substance or mixture is identified.
Section 6 No significant changes likely unless new information about the hazards
Accidental release measures of the substance or mixture is identified.
Section 7 No significant changes likely unless new information about the hazards
Handling and storage of the substance or mixture is identified. For REACH-registered substances
and mixtures containing registered components, the risk management measures
described should be consistent with the exposure scenario if provided.
Section 8 Section 8.1 – Derived no effect levels (DNELs), derived minimum effect levels
Exposure controls/personal protection (DMELs) and predicted no effect concentrations (PNECs) provide additional
information about safe exposure levels for human health and the environment
and will be included for registered substances when required as part
of the registration, and for registered component substances of a mixture.
When carrying out your workplace risk assessment, you should try to ensure
that exposure of workers and the environment is reduced through appropriate
risk management measures to levels below the DNEL, DMEL and PNEC.
Section 8.2 – For REACH-registered substances and mixtures containing registered
components, the risk management measures described should be consistent with
the exposure scenario if provided.
Section 9 Section 9.1 – This section will include a more comprehensive set of physico-
Physical and chemical properties chemical properties which should be useful in carrying out risk assessments.
Section 10 No significant changes likely unless new information about the hazards
Stability and reactivity of the substance or mixture is identified.
Section 11 Section 11.1 – As substances progress through the REACH registration process,
Toxicological information more data should become available and this section will include more detailed
information about the expected health effects of substances and mixtures,
and test data to support these conclusions.
Section 12 Section 12.5 – In future, SDSs should indicate whether an assessment has
Ecological information been carried out to determine if the substance or any component substances
of a mixture have been assessed for PBT (persistent, bioaccumulative, toxic)
or vPvB (very persistent, very bioaccumulative) properties.
Section 13 No significant changes likely unless new information about the hazards
Disposal considerations of the substance or mixture is identified.
Section 14 No significant changes likely unless new information about the hazards
Transport information of the substance or mixture is identified.
Section 15 Section 15.1 – This section will no longer contain information about
Regulatory information the labelling of the substance or mixture. It will include details of any specific
national regulatory requirements, if applicable. It will also include details of any
authorisation or restriction under REACH for the substance or component
substance of a mixture.
Section 16 No significant changes likely unless new information about the hazards
Other information of the substance or mixture is identified.
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Chemicals at work – a new labelling system
to both the DSD/DPD and In accordance with the Classification, Labelling and Packaging Regulation (EC) No 1272/2008
Acute Toxicity (Oral) Category 4, H302 Harmful if swallowed
CLP for substances and Skin irritation Category 2, H315 Causes skin irritation
Eye irritation Category 2, H319 Causes serious eye irritation
for mixtures already 2.2 2.2 Label elements
labelled according to
CLP until 1 June 2015
Warning
H302 Harmful if swallowed
Label information H315 Causes skin irritation
H319 Causes serious eye irritation
P280 Wear protective gloves/protective clothing/eye protection/face protection
including any pictograms P301 + P312 IF SWALLOWED: Call a POISON CENTRE or doctor/physician if you feel unwell
P302 + P352 IF ON SKIN: Wash with plenty of soap and water
P305 + P351 + P338 IF IN EYES: Rinse cautiously with water for several minutes, remove contact
lenses, if present and easy to do. Continue rinsing.
P337 + P313 If eye irritation persists: Get medical advice/attention
P101 If medical advice is needed, have product container or label at hand
44
7. Appendices
Information on the five worker protection directives discussed in this document: the chemical
agents directive (98/24/EC); the carcinogens and mutagens directive (2004/37/EC); the safety signs
directive (92/58/EEC); the pregnant workers directive (92/85/EEC); and the young people at work direc-
tive (94/33/EC) and links to the directives themselves can be found at http://ec.europa.eu/social/main.
jsp?catId=716&langId=en and http://europa.eu/legislation_summaries/employment_and_social_policy/
health_hygiene_safety_at_work/index_en.htm.
National helpdesks
Information on the REACH and CLP helpdesks in 27 member States can be found at
http://echa.europa.eu/help/nationalhelp_contact_en.asp
Recommendations on the transport of dangerous goods; Manual of tests and criteria; United
Nations; 2010 (download free of charge from http://www.unece.org/trans/danger/danger.htm)
45
Chemicals at work – a new labelling system
MS Excel file of signal words, hazard statements and precaution statements in 23 languages
http://ec.europa.eu/enterprise/sectors/chemicals/files/ghs/signalwords_hs_ps_en.xls
Guidance for employers on controlling risks from chemicals – Interface between CAD and REACH
at the workplace
http://ec.europa.eu/social/BlobServlet?docId=6126&langId=en)
Guidance produced by the European Agency for Safety and Health at Work (EU-OSHA)
(in 19 languages)
Facts 40 Skin sensitisers
(http://osha.europa.eu/en/publications/factsheets/40/view)
46
Guidance produced by Member State competent authorities and other national organisations
Link
Austria WKO – Das GHS-System in der Praxis – Ein Leitfaden zur Einstufung und Kennzeichnung in der EU
http://portal.wko.at/wk/dok_detail_file.wk?angid=1&docid=1272806&conid=450339
Belgium Chemicals: read the label, it protects you
CLP helpdesk – Frequently asked questions
Cyprus CLP poster
France INERIS: Labelling and classification of chemical change: an overview in 15 minutes
http://clp-info.ineris.fr/files/CLP_vue-d-ensemble_banni%C3%A8re_icone.pdf
INERIS: CLP – Calendar on the transitional period
http://clp-info.ineris.fr/files/P%C3%A9riode%20de%20transition%20-%20CLP.pdf
INERIS: CLP – Frequently asked questions
Germany BAUA (2011): REACH – Info 8: Next steps under the EU REACH regulation
BAUA (2011): Frequently asked questions on CLP
http://www.umweltdaten.de/publikationen/fpdf-l/3973.pdf
Umweltbundesamt (2010): Operational implementation of the CLP regulation – The ‘five steps’ approach
Greece CLP – Brochure
CLP – Fact wallet
CLP – In brief
Determination of penalties for the performance of CLP
Iceland UMHVERFISSTOFNUN: CLP and REACH
UMHVERFISSTOFNUN: Further clarification of the provisions of CLP regulation
UMHVERFISSTOFNUN: Classification of reference materials in the preparation of reports in the classification
and labelling files
UMHVERFISSTOFNUN (2010): Regulation on classification, labelling and packaging
Ireland HSA (2010a): Reclassification and Notification of Chemicals (Webinar)
HSA (2010b): CLP Poster 1, Classification and labelling elements
HSA (2010c): CLP Poster 2, Hazard and precautionary statements
HSA (2010d): 2010 Seminar slides
HSA (undated a): classification, labelling and packaging (clp) of substances and mixtures
under EU CLP regulation
HSA (2011): Chemical distributor duties REACH and CLP
Italy http://www.lavoro.gov.it/Lavoro/SicurezzaLavoro/PrimoPiano/20110701_Lettera_Circolare.htm
http://www.salute.gov.it/sicurezzaChimica/sicurezzaChimica.html
Malta Malta Standards Authority (undated): Notification under the CLP regulation
MCCAA (undated b): The CLP regulations – Classification, labelling and packaging of chemicals
Netherlands National government (2009): Reporting implications for EU-GHS licensing authorities
Senter Novem (2009): Note EU–GHS implications for licensing authorities
SIRA Consulting (2008): Dutch research into the consequences of the CLP Regulation for the Dutch business
National government (undated): EU–GHS – Education
National government (undated): EU–GHS FAQs
Sweden KEMI: Klassificering, märkning och förpackning
NKG (2010): CLP workshop
KEMI (2009): Poster of present and new symbols
United Kingdom RoSPA(2009): Young workers
Business Link (undated): Employing older workers
Directgov (undated): Employers’ health and safety responsibilities
HSE (undated): A guide for new and expectant mothers who work
SOHAS (2007): Health and safety at work for pregnant women and new mothers – Information for employers
47
Chemicals at work – a new labelling system
48
European Commission
Over the next few years, new legislation known as the CLP regulation is changing how chemical products are
classified to identify hazards, and how this information is communicated on labels and safety data sheets (SDSs).
This document is intended to provide practical guidance to employers and workers on how the directly acting
CLP regulation (Regulation (EC) No 1272/2008 on the Classification, Labelling and Packaging of Substances
and Mixtures) will affect the following worker protection directives:
• chemical agents directive (98/24/EC);
• carcinogens and mutagens directive (2004/37/EC);
• safety signs directive (92/58/EEC);
• pregnant workers directive (92/85/EEC);
• young people at work directive (94/33/EC).
These directives have been implemented in the national legislation of each Member State. Information on this
legislation and general guidance on how to comply will normally be available from the authorities responsible
for occupational health and safety in each Member State.
http://ec.europa.eu/social/
www.facebook.com/socialeurope
ISBN 978-92-79-28347-5
doi:10.2767/9499