Bulk chemicals

Bulk chemicals are defined as those chemicals which are stored in tanks, and moved by pipeline, or using bulk tanker.

Bulk chemicals are not labelled for CLP for transport, as only Transport labelling is required on a bulk tanker. However, it is likely that a Safety Data Sheet will be required for the product under ADR (and one may be requested for non-hazardous chemicals as well, if you use an external transport company).  If you move products about your site internally, these rules do not apply, but it is good practice to follow them.

Prior to CLP, bulk chemical tanks were not labelled for CHIP, but often with just the product name, or the Transport symbols.  However, they are now required to be labelled for CLP pictograms, under the requirements of the Health and Safety (Safety Signs and Signals) Regulations 1996, see http://www.legislation.gov.uk/uksi/1996/341/contents/made, as updated by the Classification, Labelling and Packaging of Chemicals (Amendments to Secondary Legislation) Regulations 2015 , see  http://www.legislation.gov.uk/uksi/2015/21/contents/made .

Note that, as well as the requirement to display CLP pictograms on a bulk storage tank, it is  usual practice to put the product name on a tank sign, particularly if the tank is used for different products and not dedicated to a single product.

The full practical requirements are given in L64,Safety signs and signals.  The Health and Safety (Safety Signs and Signals) Regulations 1996. Guidance on Regulations, which can be downloaded as a free pdf from http://www.hse.gov.uk/pubns/books/l64.htm (a priced hard copy is also available to purchase).  This document describes labelling practice for both bulk tanks, and also pipework, although the potential for overlap with BS 1710:2014, Specification for identification of pipelines and services is recognised in the guidance, and this can be purchased from https://shop.bsigroup.com/ProductDetail?pid=000000000030283829 .

Safety Data Sheets are required for all products placed on the market, so an SDS may not be required for intermediates made and consumed on site, but will be required for all other bulk chemicals.

To summarise:

• all bulk chemicals should be classified for CLP
• bulk chemical storage tanks on site should be labelled with CLP pictograms (or equivalent hazard information)
• pipework may also be required to be labelled with CLP information in certain circumstances
• bulk chemical transport tanks should be labelled for Transport, and the driver provided with an SDS
• the recipient of a bulk chemical product should also receive an SDS