Compliance and safety for the supply of chemical products
CLASSIFICATION
Classification according the Globally Harmonised System - Our services
Alchemy Compliance can classify and label your chemical products according to the GHS system, and produce compliant safety data sheets for the increasing number of countries that have adopted the GHS system.
Alchemy Compliance has extensive experience in the classification of chemical substances. We can advise on the GHS classification using available data, such as study reports, literature searches, and structure–activity relationships.
Alchemy Compliance can also classify preparations, either from test data, or by calculation according to the GHS formulas.
Background to the Globally Harmonised System for Classification
The United Nations (UN) concluded that small and medium enterprises (SMEs) were effectively precluded from international trade in chemicals due to the burden of regulatory compliance. A primary concern is the classification and labelling of chemical products for supply. This is the set of criteria for determining the hazard class (eg flammable, irritant), and various subdivisions within each class (eg very toxic, toxic, harmful for acute toxicity). This classification is highly visible to the customer as symbols and hazard phrases, directly affecting marketing strategy, and has a substantial knock-on effect for downstream operations such as worker safety, provision of safety data sheets (SDSs), and waste management. For instance, preparations containing substances that are classified as carcinogenic, mutagenic, or toxic reproduction cannot be marketed to the general public.
However, chemicals may have different official classifications in different regulatory jurisdictions, such as the EU and US. What is toxic in the EU may not necessarily be toxic in the US. Further complications are the different systems of classification for supply and transport. This diversity of regulation means that chemical companies often face complex compliance issues, which can lead to delays in marketing, product withdrawals, and reduced profitability.
The UN’s solution to these woes is the Globally Harmonised System of Classification and Labelling of Chemicals (GHS), which is intended to reducing costs of global trade in chemicals through harmonising the classification criteria across product types and geographical regions, harmonising the hazard communication elements (labelling and Safety Data Sheets), and extending the scheme to those countries that do not have a developed chemical control system. The GHS should also offer better protection to man and the environment through an increased coherency, and also because of easily understood symbols and readily translatable warning statements.
The GHS was designed to take the best elements of the most widely used systems for chemical classification: those in the US, Japan, Australia, Canada and the EU, plus the harmonised system already in place for the classification of substances and preparations for transport. The UN required that the new system would not lead to a reduction in safety standards, with a consequence that the most stringent aspects of each scheme were taken on board.
EU Implementation of the GHS
The CLP Regulation is the EU implementation of the United Nation’s (UN) Globally Harmonised System of Classification and Labelling of Chemicals (GHS). As the name suggests, the aim of the GHS is to provide recommendations for classification criteria at an international level, which will be implemented in all major industrialized nations, and provide an ‘off-the-peg’ solution for developing countries.
The ideal situation would be that all countries would fully adopt the GHS, so eliminating differences in chemical product classification throughout the world. However, there are important reasons why this ideal situation is unlikely to be realized. The GHS criteria are recommendations, and do not act directly in any country. Each country, or trade area (eg the EU), may bring in the GHS as they see fit. Thus the EU Commission has adopted those parts (‘building blocks’) of the GHS that most closely resemble the classification system under the DSD/DPD. The EU has not adopted the GHS ‘building blocks’ related to classification in the following categories:
- Flamm Liq 4
- Acute Tox 5
- Skin Irrit 3
- Asp Tox 2
- Aquatic Acute 2 and Aquatic Acute 3
It is likely that other trade areas will also legislate classification criteria that differ from full GHS recommendations, so that complete harmonization will not prevail.
Furthermore, the GHS is not static. The GHS is published biennially, in odd-numbered years, to incorporate the latest changes agreed at international level. The EU CLP Regulation, and equivalent legislation in other trade areas, may well lag behind the most current version of the GHS. CLP is not the same as GHS!
Nevertheless, the GHS will ensure a much greater harmonization of classification and labeling between trade areas than was previously possible, allowing consistent use of pictograms and warnings, with a consequent reduction in trade barriers, and an increase in safety.
Also, the UN GHS and EU CLP criteria are more similar to the UN criteria for classification for transport of dangerous goods, so that there will be more harmonization between supply classification and transport classification. This is particularly apparent for physico-chemical hazards, such as flammability or explosivity, where the UN transport test methods and criteria have been transposed largely unchanged into the CLP Regulation.
Finally, the CLP Regulation acts directly in each EU Member State, ensuring a greater degree of harmonization with the EU, compared to the DSD classification scheme which required transposition into Member State legislation (eg the ‘CHIP’ Regulations in the UK).
The EU CLP Regulation came into force 20 January 2009. However, the Regulation contains provisions for a transition from the DSD/DPD classification scheme to the new system (Article 61 of the CLP Regulation), which lasts until 1 June 2015.
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