web site analytic

Hazard Communications

To ensure their safe use and handling, manufacturers and distributors of chemicals must clearly identify and communicate information regarding their properties and potential hazards. The two primary mechanisms for conveying this data are Material Safety Data Sheets (MSDS) and Product Labels. Both are driven by regulatory requirements, voluntary product stewardship programs, product liability issues, and various other issues specific to each region of the world.

There are two major initiatives currently driving the format and content of hazard communication programs:

  1. The Globally Harmonized System (GHS) for Classification and Labeling, and
  2. The EU’s Classification, Labeling and Packaging (CLP) requirements.
The Globally Harmonized System (GHS)

The Globally Harmonized System of Classification and Labeling of Chemicals—called GHS for short—is a United Nations led initiative to standardize the use of hazard warnings based on consistent criteria. At a glance, the GHS has the following basic elements:

  • Classification Criteria
    • Health and Environmental Hazards
    • Physical Hazards
    • Mixtures
  • Hazard Communication
    • Labels (including pictograms)
    • Safety Data Sheets

The ultimate goal of the GHS initiative is to create a universal standard for the classification and labeling of chemicals and hazardous substances or mixtures. Achieving a harmonized system will result in numerous changes and new requirements in terms of hazard communication within the workplace, product labeling and employee training—all of which will involve significant time and money. To comply with GHS-based regulations, all existing chemical products will need to be re-evaluated against this system's criteria. This means most Material Safety Data Sheets (MSDSs) and labels will need to be revised in format and content. These changes will need to be made to comply with new European Union Regulations by December 1, 2010 and OSHA has now proposed regulations to implement GHS elements.

While the intent is a uniform global standard that should streamline and improve communications, the reality is that GHS is being implemented on a country by country and regional basis, resulting in significant variability. The GHS has been implemented through various regulations in Japan, China, Korea, Taiwan as well as the European Union (EU). Within the United States, the GHS is the basis for proposed changes to the OSHA Hazard Communication Standard.

Classification, Labeling and Packaging (CLP)

As part of new regulatory requirements for hazard communications, the European Union has legislated strict Classification, Labeling and Packaging (CLP) guidelines which are drawn from the United Nation's Globally Harmonized System (GHS). After a transitional period, the CLP Regulation will replace the current EU rules for classification, labeling and packaging of substances (Directive 67/548/EEC) and mixtures (Directive 1999/45/EC). Substance classification and labeling must be consistent with the new CLP rules by December 1, 2010. The compliance deadline for chemical mixtures is June 1, 2015 to comply.

There are differences between how GHS is being implemented in the EU through CLP regulations and the way GHS is being implemented in many other countries.

The CLP regulations require manufacturers, importers, distributors, and downstream users, such as formulators who mix products to:

  • Reclassify and re-label substances by December 1, 2010. However, to address products already in the supply chain or "on the shelf" (substances already in the market and classified, packaged and labeled before December 1, 2010) - there is an additional grace period of two years, until December 1, 2012.
  • Submit notification to the European Chemicals Agency (ECHA) of the classification and labeling of their substances (unless this same data already has been supplied under the EU’s REACh registration.)
  • Reclassify and re-label mixtures by June 1, 2015. Similar to the extended grace period for chemical substances, a further two-year transition period is granted for chemical mixtures that are already classified, packaged and labeled, and placed on the market before June 1, 2015.

Unlike the EU's REACh registration requirements which are based on production volume, CLP requirements apply to all substances and mixtures irrespective of the volume supplied. This means that notifications to ECHA will be required for substances manufactured or imported even in small quantities, as well as those manufactured or imported in quantities greater than one ton per year. Furthermore, the CLP Inventory notifications are known to be a challenging and labor intensive exercise. As an example, if notifications are completed using the IUCLID 5 application, ECHA estimates 200 fields will need to be completed for each notification.

ENTRIX Hazard Communications Experience

ENTRIX has expertise in assisting clients develop effective Hazard Communications. Our professionals are well-versed and experienced in complying with GLH requirements, submissions and customer requests for GHS “compliant” documents. Similarly, we can help navigate and comply with the CLP requirements and CLP Inventory submittal obligations.

Our nationwide team of chemists, toxicologists and many other subject matter experts are skilled in providing specific input on chemical, physical, toxicology and environmental properties, which form the basis for hazard communications.

If your organization has specific questions or would like to discuss any of these programs further, please contact John Phillips, Vice President and Technical Director at 517.381.1434 or Tom Grumbles, Senior Consultant at 713.662.1991 or email them by clicking here.