1st December this year will see the first registration deadline under REACH for those manufacturers/importers supplying a substance above 1,000 tonnes/year. Perhaps slightly less well publicised but equally important is the coming into force of key provisions of European Regulation (EC) No 1272/2008 on Classification, Labelling and Packaging of Substances and Mixtures, otherwise known as the CLP Regulation. This Regulation is the method by which the EU has adopted the agreement on a Globally Harmonised System (GHS) on the classicisation, labelling and packaging of chemicals. Changes to the system include terminology changes such as ‘hazardous’ replaced by ‘dangerous’, ‘risk phrases’ replaced by ‘hazard codes and statements’, ‘safety phrases’ replaced by ‘precautionary statements’ and ‘warnings’ (irritant, corrosive etc.) replaced by ‘signal words’ (warning, danger etc.). Although the legislation was approved in January 2009, it won’t come fully into force until June 2015, and the transitional period coincides with some of the key REACH deadlines. However, the CLP Regulation is going to have a much wider impact than just REACH as much national legislation is based on the existing CLP system. For example, the classification of hazardous waste is partly based on risk phrases, so will the Hazardous Waste Regulations have to be overhauled? It will be interesting to see how the knock-on effects of the CLP Regulation will be dealt with in the UK. The transitional period will also mean an overlap between the new and old systems, so some downstream users of chemicals will receive data sheets from one supplier using the old system and some from a different supplier using the new system! Interesting times…
