CLP Regulation

Here's a post from Catherine:

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…

Introducing Catherine

I’d like to introduce you to my colleague, Catherine. She started at ECUS nearly four years ago now as the admin assistant whilst working on her LLM in Environmental Law. Now, of course, she is a key part of our Environmental Management team. We are all very impressed as she dashes off after work to practice with her salsa band, her folk metal band and her ladies recorder group or to various of her gigs. She even finds time to go to see other bands play.

We love Catherine. She is rather quiet when she’s not whistling complicated classical tunes but she is great fun to be around with a wicked sense of humour, an addiction to strong tea and a wonderful ability to make sense of environmental legislation. Even better, she is a completer/finisher. Nothing pleases her more than putting the final touches to a report, PDFing it and sending it off. She’ll even QA my reports for the joy of another piece of work completed. And she looks lovely in turquoise. What’s not to love?

I don’t want to paint too rosy a picture though. Catherine is a music snob. She finds the ‘music’ I listen to offensively banal. I will admit to finding her taste a little too hardcore for my middle-aged ear. When we travel together we tend to compromise on Classic FM.

Anyway, at the end of a very busy week she has promised me that she will write a short piece about the new Environmental Permitting (England and Wales)(Amendment)(No.2) Regulations. How exciting!

(Catherine grumbles that saying she finds my music offensively banal is a little harsh. It's just, she says, not to her taste.