CLP after Brexit

At the time of writing, 28-03-2017, it is not known whether CLP will be adopted by the UK after Brexit, or whether we will go for immediate adoption of GHS, the Globally Harmonised System, which is the “mother standard” of CLP.

TT Environmental is a member of the the Chemical Regulations Self Help Group, which has participated in the Inquiry on “The Future of Chemicals Regulation after the EU Referendum”.

The Self Help Group has recommended that the UK should:

• adopt GHS directly by reference to the UN Purple Book, rather than adopting CLP as a whole (analogous to the way that ADR is adopted by reference to the Orange Book)
• adopt Safety Data Sheets from GHS rather than from REACH, so all hazard communication legislation is held in one place
• harmonise the adoption of GHS so that it mirrors the revision and parts adopted by CLP, so the GHS components of UK-GHS are identical to CLP
• adopt the non-GHS parts of CLP from CLP itself, so that these are also identical to CLP (these include the EUH statements, and the Harmonised Classification list in Table 3.1, Annex VI to CLP)
• have UK-GHS as a minimum standard, allowing other GHS jurisdictions to provide labels and SDSs containing extra information, and avoid the need to relabel or reissue SDSs when selling into the UK

Adopting these recommendations would mean that:

• there would be no difference between the classification of materials for CLP and UK-GHS
• CLP labels and UK-GHS labels would be identifical
• there might be differences between EU REACH-compliant SDSs and UK-GHS SDSs, but as this would include extra information, such as the Annex to REACH, and information such as REACH registration numbers, this would be acceptable in the UK
• any non-EU GHS jurisdictions which comply with UK labelling and SDS standards would be able to keep their labels and SDSs when exporting into the UK

The full submission to the Inquiry can be viewed online at http://data.parliament.uk/writtenevidence/committeeevidence.svc/evidencedocument/environmental-audit-committee/eu-chemicals-regulation/written/45626.html .

For more details on the work of the Chemical Regulations Self Help Group, see https://www.chemselfhelp.co.uk/ .