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Globally Harmonised System and the CLP Regulation or "Oh no, not COSHH again!"

The UN Globally Harmonised System aims to make all classification of substances harmonised the world over to reduce confusion and aid risk reduction measures. This system was implemented across the EU by the Classification, Labelling and Packaging of Substances and Mixtures Regulation (CLP Regulation) which came into effect 20 January 2009, subject to a very lengthy transitional period running up to 1 June 2015.

Most of the duties are on the Suppliers with regard to CLP but end-users still need to be aware of the changes in phrasing, pictograms and safety data sheets.

What has changed?

Pictograms

There are now only 9 pictograms, all consisting of a red diamond frame containing a black hazard symbol on a white background. The old Black framed orange squares will no longer be used as shown in the example below:

 

 

 

All pictograms relating to transport will remain covered by the Transport of Dangerous Goods Regulations.

Signal words

Each substance will now have either ‘Danger’ or ‘Warning’ on the label, unless it is deemed of such low hazard to not require one.

  • Danger = more severe hazards
  • Warning = less severe hazards

What about Risk and Safety Phrases?

Hazard and Precautionary statements now replace all risk and safety phrases.

Hazard statements

These are standardised statements about the nature of hazard and the degree of hazard presented by the substance. Each hazard statement has a corresponding identification code, however this may not be used instead of the written hazard statement on the packaging/safety data sheet and must only be used for reference.

Precautionary statements

These are brief statements to provide measure to undertake to minimise or prevent effects from physical, health or environmental hazards. These include first aid measures and can be a pictogram (see above) or a written statement.

Labels

All labels of substances must conform to theGHSvia theCLP.

How does this affect end-users?

End-users shouldhave started to take receipt of substances with the new packaging from 1st December 2010 however at Park City we are aware of some suppliers who have only just begun changing their packaging and safety data sheets, therefore this information should be brought to the attention of all staff who may come into contact with such substances and/or mixtures as soon as possible.

There is no explicit requirement to re-label any current stock or old stocks, however you may wish to re-label your current stock with the new system from 1st January 2015 to make sure users become accustomed to the new system and that old stock is treated in the same manner as new stock prior to the full change over.

What about your COSHH assessments?

The HSE state that COSHH assessments should be revisited to ensure that they are kept up to date and as an employer you should do this regularly. This does not mean that the whole assessment process will have to be repeated at each review as the purpose of a review is to see if the existing assessment is still suitable and sufficient. If it is, then you do not need to do any more.

If it appears that the assessment is no longer valid a review does not mean that the whole assessment has to be done again, only those parts that do not reflect the new situation need amending.

The assessment should be reviewed immediately if:

There is any reason to suppose that the original assessment is no longer valid.

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