CLP background summary
Hazard communication for chemicals is a very important task, as it is vital in helping people use chemicals safely, and preventing accidents.
In the UK, the 1974 Health and Safety at Work Act imposes a duty on everyone to try to ensure that their activities do not affect people at work, or the general public, and this acts together with specific chemical legislation such as CLP and REACH.
As well as the legal duty to try to classify chemicals and write SDSs as accurately as possible, we are under a moral obligation to do this as well as possible, to prevent harming other people, or the environment.
The sequence of hazard communication is – classify product for CLP; produce label; write SDS. There may be other duties to communicate information in the supply chain, or to ECHA.
When classifying chemicals and writing SDSs, it is important to understand how your product is likely to be used, and to be able to put yourself in the shoes of users with little or no chemical knowledge.
CLP is the Classification, Labelling and Packaging Regulation for chemicals for supply (that it opened and used by someone), and is an EU “directly acting” regulation rather than a UK regulation.
CLP is based on the UN’s Global Harmonised System (GHS), which itself is closely linked to the Transport of Dangerous Goods, with many similar classification hazards and thresholds. However, not all GHS hazards have been adopted into CLP.
CLP is also based on CHIP, which preceded it for classifying chemicals for supply, and still contains parts of CHIP, like the list of Harmonised Classifications, and EUH label statements.
The overall effect is that GHS and CLP have various points of difference, and are likely to continue to be different for some time to come.
CLP is also interlinked with REACH, which currently regulates Safety Data Sheets, and which also provides a source of CLP classification data.
As well as the direct effects of CLP and REACH, anyone classifying chemicals in the UK needs to be aware of Duty of Care, which at times may over-ride some aspects of the European regulations, for instance in keeping labels and SDSs up to date.
CLP is likely to be replaced after Brexit, but what will happen is currently not known.