Know About CLP-REACH Specific Classification of Specialty Chemicals

Business in chemicals in the EU is different and more complex because of REACH and CLP regulations that are inherently more complex. CLP regulation defines criteria for labeling, classification, and packaging of hazardous chemicals in the EU, whether these are for industrial use or for consumer use, even chemical products used in small quantities. CLP is wider in scope as it covers end users and effects on the environment in greater detail.

It becomes even more complex when the GHS hazard classification in CLP/REACH applies to a hub sector specific classification of specialty chemicals as are grouped in annexure VI. It requires careful consideration. Part I relates to list of harmonized classification and labeling. Part 2 defines guidelines for document preparation and part 3 lists the hazardous substances. It requires an expert to unravel the complexities of the document and arrive at the right classification category. One must take into account index numbers, EC numbers, CAS numbers and international chemical identification of a hazardous substance.

In addition to taking care of exceptions that might require the substance to be classified under another head, one must also consider the percentage of a chemical in a formulation. In some cases, some substances may fall into several group entries in which case the most severe classification applies. The various hazard classes are explosive, flammable gasses and aerosols, the oxidizing gas, gasses under pressure, flammable liquids and others including germ cell mutagenicity and carcinogenicity. Hazard statement codes apply to each substance and its classification. Labeling codes are also quite well defined and must conform to annexure V with the use of appropriate signal word code, hazard statement code as specified in annexure III and codes for supplemental statements pursuant to article 25(1). It becomes more complex to understand and apply since there are qualifications such as when a chemical is stabilized by the use of an additive in which case it may need to be classified under another head. In short, the REACH and CLP registration process impose strict regulatory requirements for chemical import and distribution, especially if they are specialty chemicals with impact on human health and environment.

Companies that wish to export to the EU must not only ensure full compliance and prepare and exhaustive document but they must also ensure that such documents are translated into local languages without losing any of the meaning in the process of translation. In cases where formulations are proprietary then it requires special expertise to present and prepare documents as well as obtain the exemption from declaring the secret while remaining in full compliance, a no mean task. This is where employing experts to take care of CLP GHS hazard classification and documentation comes in useful.

ECHA not only prepares all the guidelines for harmonized classification but these are constantly updated and this is yet another reason to hire experts who keep themselves updated with latest modifications and updates to Regulation (EC) 1907/2006 and 1271/2008 for the European Union.

GHS SDS and Importance of Keeping Them Updated

Chemical manufacturers and importers/distributors must maintain safety data sheets of each product and these must be aligned with OSHA’s Haz Com 2012 guidelines the deadline for which has passed but some manufacturers and importers have still to comply 100%. Failure to comply with the deadline results in penalties and some companies have paid such fines.

Non-compliance happens because the upstream supplier has not supplied the GHS SDS and the user/dealer has not been diligent enough to check this. Manufacturers and dealers must first check their inventory and tally this against the SDS in their possession to make sure all such data sheets are updated. Checking inventory regularly is a good practice and helps them find out about missing SDS. If they buy chemicals or formulations then they must ask for and receive SDS from the supplier. A record of such communication is a safety measure should the supplier not deliver the data sheet. He can submit such proof of communication in order to prove his innocence and avoid a fine. Updated SDS is also necessary in order to train workers in safety measures and implement these at workplaces besides protecting the environment.

The SDS is necessary in the case of substances and mixtures that match the defined hazards under the GHS system. OSHA has implemented certain GHS implementations and it is likely that as hazards are redefined in future, it will require chemical manufacturers/importers/dealers to update their GHS safety data sheets accordingly. As can be seen, preparation of the SDS is a complex task from the perspective of compliance and from the perspective of providing information in a concise yet clear way for workers to be fully informed about safety measures. Should new information come to light in future about hazards then such data sheets need to be amended accordingly and the cycle of approval, as well as worker training, starts again. It is a continuing process towards highest levels of safety at workplaces and safety for an environment. The safety labels to need to be updated and standardized along with the data sheets not only for compliance purposes but to ensure better safety in the supply chain.

From another angle, the latest and updated SDS helps in trade. Buyers and even authorities in that country may insist on the most recent SDS document. Suppliers are supposed to furnish a data sheet along with the shipment or they and their buyers may face difficulties in clearing consignments. It could jeopardize future supplies. The SDS may need to be furnished in printed format and it is also acceptable to access it an electronic format accessible from an online database.

Given the present regulations and anticipated future changes, it would be wise for chemical manufacturers and exporters/importers to retain experts in preparation and maintenance of SDS as well as conversion to electronic format and translation besides training if they are to remain fully compliant today and in future. Experts not only help with the all these processes but they are also at hand should any major policy changes occur in future. Exporters, importers, and manufacturers can focus on the more important aspect of trade while SDS preparation and compliances are handled by experts.

Workplace Safety: Get Employees Involved

For some employers’ safety is the most important aspect of their business, a healthy investment which their company strives to promote throughout the workplace. Yet others see safety as code for an over burdensome waste of time, money, and effort. For businesses struggling with safety culture improvement, here are a few tips to raise and increase awareness.

Increase the importance and awareness of the benefits of safety in the work place. Employees may be hesitant to embrace safety if they feel that it does not apply to them. It is important that employees understand that even if they are not working on machines or climbing to dangerous heights, that they are still at risk of injury. Include information and statistics on real life safety topics such as food preparation, or slip and falls in rest rooms or walking down a hallway. Topics like these will show employees that there are risks involved with every job! Videos of real workplace safety hazards and community safety programs can help get the point across. Encourage employees to include their family members in the safety message. Injuries can affect people at home or at work.

Another great way to involve employees in the safety environment and concern of the business is by creating a new safety committee/board, or inviting them to join your existing safety committee/board or if no committee /board exist, to have a monthly meeting with the employer to discuss the safety aspect. Make sure management allows employees to participate during work time. Employees may not want to take their free time to discuss this matter and it confirms that the employer is respectful of the employees’ time. A safety meeting should have representatives from all levels of the organization, from management to laborers. This gives employees the opportunity to express any concerns they may have along with efforts to ensure those issues are addressed with everyone’s impute. Sometimes employees may provide options that the employer can utilize and this will buster good will between all parties. The committee can also create goals for safety compliance, including rewarding employees for participating or making safety improvements.

Since safety does not remain of the minds of employee every second, a simple way to keep safety in the minds of your employees is to include a reminder in their paycheck envelopes, send emails, text messages or safety news update boards in employee areas. Providing and sharing safety tips, statistics, and real-life stories about other companies like your own are just a few examples of what can be included. Ask your employees for suggestions or ideas on what they would like to learn more about. Additional, host safety training seminars or meeting at the workplace. These meeting should take place during work hours. This will keep safely a little more on the minds of the employee and provide safety updates.

The focus of the committee and the employer encouragement to the employee should be to help the employer identify the hazard and correct it. Encourage employees to look for hazards in the workplace and report them to the appropriate personnel to correct the problem! Make workplace safety a habit not a hassle.