Harmonising the global language of safety
The convergence of several chemical reclassification and labelling initiatives being implemented in the global business arena to boost health, safety and environmental protection.
Stephen Harrison, Linde Gas
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The convergence of several chemical reclassification and labelling initiatives being implemented in the global business arena to boost health, safety and environmental protection to an unprecedented level is poised to have a monumental impact on the world’s industrial sector.
Together with other chemical sectors which use raw materials and which introduce new formulae, the petrochemical industry is being required to make rapid and sweeping changes to comply with a whole new level of regulatory requirements. The new legislation impacts on product registration, classification and labelling, packaging and transportation, storage, product information and product disposal.
Launched in 2005, the United Nations’ Globally Harmonized System of Classification and Labelling of Chemicals (GHS) affects more than sixty countries and, since 1 December 2010, directly impacts all chemical substances in European Union (EU) countries. The GHS aims to achieve uniform worldwide criteria for classifying chemicals according to their health, environmental and physical hazards. This uniformity will also apply to hazard communication requirements for labelling and Safety Data Sheets. The GHS is not a formal treaty, but is rather a non-legally binding international agreement. In addition to improving health and safety in this arena, a key UN objective with this initiative is to make it easier for companies to conduct international trade.
The GHS addresses the classification of chemicals by types of hazard and proposes harmonized hazard communication elements, including labels and safety data sheets. It aims to ensure that information on chemical hazards is made available to enhance the protection of human health and the environment during the handling, transportation and use of these chemicals. The GHS also provides a basis for harmonization of rules and regulations on chemicals at national, regional and worldwide level, an important factor for trade facilitation.
Reach and CLP
The European Union has already taken the lead in the harmonization quest with its REACH regulation on chemicals and their safe use, which applies to substances manufactured or imported into the EU in quantities of 1 tonne or more per year. Implemented in June 2007, REACH deals with the Registration, Evaluation, Authorization and Restriction of Chemical substances. The purpose of this regulation is to ensure a high level of protection for human health and the environment. This includes the promotion of alternative methods for assessment of hazards of chemicals, as well as the free movement of substances on the market of the EU. REACH makes industry responsible for assessing and managing the risks posed by chemicals and providing appropriate safety information to their users. Substances in volumes over one ton per year that are either manufactured or imported into the EU (even in preparations/mixtures and articles), now have to be registered.
The CLP regulation, a more recent EU initiative implemented in January 2009 has the dual objectives of facilitating international trade in chemicals and improving protection of human health and the environment. CLP aligns the EU system of Classification, Labelling and Packaging of substances and mixtures to the GHS. It is expected to facilitate the harmonized communication of hazard information of chemicals and to promote regulatory efficiency. It complements REACH and replaces the current system contained in the Dangerous Substances Directive and the Dangerous Preparations Directive. CLP introduces new classification criteria, hazard symbols (pictograms), signal words and labelling phrases (hazard and precautionary statements), while taking account of elements which are part of the current EU legislation.
CLP provides a transitional period to allow a gradual migration from the existing system to the new regime. These arrangements cover a transitional period of up to seven and a half years from implementation.
ISO 10156: 2010
Although less formidable in implication, another critical technical standard coming into play is ISO 10156: 2010, superseding ISO 10156: 1996. This norm impacts on how mixtures of two or more products are classified and where and how they should be labelled, transported, used and stored. Once this revision comes into effect, the impact on affected products could include a new identification label, a new cylinder shoulder colour to indicate the change from either a non-flammable to a flammable mixture, or from a flammable to a non-flammable mixture, updated safety data sheets to include the changes for cylinder safety and transportation and a different cylinder valve outlet.
In terms of the end user, storage conditions may now need to be reviewed, including permits for storage of dangerous substances. Transport conditions will need to be revisited, as will risk assessment to update operational procedures according to the new risk assessment outcome. Gas control equipment and supply system compatibility may also need to be checked, as changes may be required for both cylinder connections and supply line labelling.
Linde Gases’ Stephen Harrison, Head of Specialty Gases and Specialty Equipment, explains it this way: “Although the physical properties of gases do not change, our understanding of the physics of these gases has certainly changed and this impacts on whether or not they represent a safety hazard. The implication is that even though a product someone may have purchased in the past may have been labelled as non-flammable, in the future it might be labelled as flammable.
“And there’s knock-on effect associated with this. The implication to customers is how they will train their personnel to handle these gases in future. If the product is now labelled as flammable, they’ll need to look at factors such as fire safety procedures, transport measures and storage configurations. Previously used regulators may not do the trick anymore, because the outlet valve has changed to comply with a new classification.”
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