CLP Regulations – are you compliant?

Simon RobinsonSimon Robinson, Director at Safeware Quasar is this month's guest blogger.

The highly publicised June 1st deadline for CLP implementation of chemical mixtures finally arrived this Monday, to the best of my knowledge we all survived and life carried on regardless. So in reality what has changed and how can we expect the regulatory landscape to evolve over the next few years?

The Classification Labelling and Packaging regulations EC No. 1272/2008 which implements the new global system for classifying chemicals and mixtures in Europe entered its final implementation phase for the classification and labelling of mixtures. This Regulation aligns previous EU legislation on classification, labelling and packaging of chemicals to the GHS (Globally Harmonised System of Classification and Labelling of Chemicals).

The CLP Regulation was published in the Official Journal 31 December 2008 and entered into force on 20 January 2009. The deadline for substance classification according to the new rules was the 1st December 2010 and for mixtures a deadline of the 1st June 2015.

Safeware through its technical support services and annual regulatory conference SafeCom has for several years been assisting its clients to develop an implementation plan for CLP to ensure business continuity and a seamless introduction of the new system. Of course, we have experienced unprecedented demand over the last 6 months for help and guidance, and we are happy to report that both our regulatory and IT support teams have been able to provide the necessary assistance to ensure our clients meet the deadlines demanded from the regulations.

Now the deadline has past what should customers prepare for in the future?

Safety Data Sheets
Amongst the excitement of the June 1st deadline a revised regulation has been published (EU 2015/830) replacing Annex II of REACH effective from 1st June 2015.
• This regulation adapts minor revisions from the 5th revision of UN GHS for Safety Data Sheets.
• Confirms the revised format for Safety Data Sheets and makes provisions for a phased implementation for compliance

Further revisions to CLP
A proposed 7th ATP to CLP is pending final approval later this year. This revision updates the list of harmonised classifications in CLP (Annex VI) with new entries and revision of existing ones.
The 8th ATP still under discussion makes amends as required by the 5th revision of the UN GHS. color scheme generator There are no dates available for implementation.

Poison Centre – Article 45 CLP updates
The Commission have announced the publication of a cost-benefit study relating to the harmonisation of information to be submitted to Poison Centres.
A working paper/review of potential harmonisation of data requirements has been drafted. The creation of a ‘unique formula identifier’ (UFI) to be included as part of the labelling requirements has been identified as a clear benefit in assisting identification of products during incidents.
The adoption of the UFI represents new costs to industry, but a clear benefit to Poison Centres and patients. The estimated costs presented within the report, are exceeded by the harmonisation savings. how to backup iphone to icloud . The impact of adopting the UFI will be reduced by using a transitional phase and again the cost savings for this element have been provided within the report. The possibility of adopting a group UFI for cases where there are large product ranges with similar compositions is also explored.
The study estimates the positive and negative impacts of a harmonised notification system of data to be transmitted to Poison Centres in accordance with Article 45 of the CLP Regulation.

Note:
Safeware Quasar a leading supplier of expert regulatory software, consultancy solutions, and support services, assesses the CLP implementation for chemical mixtures which incorporates the majority of chemical based aerosols currently manufactured.

Safeware Quasar is a BAMA member and Simon will be presenting at the BAMA Forum on the 15th October 2015.

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About BAMA

The British Aerosol Manufacturers' Association (BAMA) represents the aerosol supply chain, from suppliers of components and ingredients to Fillers and Marketers. The association offers a range of business support and advice services to members and represents the views of the industry to legislators and regulators.