CLP/REACH Update
YCF REACH Network Meeting
Syngenta Huddersfield, 9th March 2010
Janet Murfin
contents
• Quick recap on CLP
• News on REACH and CLP, including
CLP notification
• Some tips on CLP practical
implementation
YCF REACH Network meeting, 9th March 2010
2
A quick CLP recap:
• EU method of implementing UN’s Global
Harmonised System (GHS)
• Implementation in parallel with REACH
• Run alongside CHIP until 2015
• Complete new system of hazard
classification – new terms (H phrases not
R phrases), some new labels, new
categories & thresholds
YCF REACH Network meeting, 9th March 2010
3
….how labels may look (a)..
Replacing Harmful, X symbol
Immediate
low level
health hazard
Long term
low level
health hazard
New symbol
Compressed
gas
Still have Toxic symbol for substances
which seriously affect human health
YCF REACH Network meeting, 9th March 2010
4
Spot the difference – CHIP label
YCF REACH Network meeting, 9th March 2010
5
Chloroform label - CLP/GHS
YCF REACH Network meeting, 9th March 2010
6
Poster shows threshold differences(free download from Merck)
YCF REACH Network meeting, 9th March 2010
7
CLP and CHIP timelines
Now to
1/12/10
1/12/10
1/6/13
1/6/13 – 1/6/15 – 1/6/18
1/6/15
1/6/18
onward
Substances
CLP
optional
CLP and CHIP both
mandatory
Mixtures
N/a
CHIP mandatory
CLP optional
CLP implemented
in full, CHIP gone
• 5 year dual classification period for substances
(CLP label, CHIP & CLP SDS); voluntary for
mixtures (CHIP label, CHIP only or CHIP & CLP
SDS)
• Also CLP notification requirement in 2010
YCF REACH Network meeting, 9th March 2010
8
Sodium Hypochlorite issue
• Most YCF REACH network members
are aware of the Sodium
Hypochlorite reclassification to R50,
bringing it into COMAH
• CLP will mean COMAH/SEVESO will
be rewritten in the new language,
but this will be 2011/2012, not
immediately
YCF REACH Network meeting, 9th March 2010
9
Important point for all REACH
registrants – 1st ATP to CLP
•
•
Reclassifications coming into force 1st Dec 2010
may bring forward REACH deadline
Available at http://eur-
lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2009:235:00
01:0439:EN:PDF
•
•
Check your substances in the pdf by doing a
“find” on the CAS numbers or chemical names
(they come up twice, in GHS and CHIP tables)
Not everyone is aware of changes, you may
need to email other pre-SIEF/SIEF members
YCF REACH Network meeting, 9th March 2010
10
News: first REACH-IT upgrade has
been successful
• Increased capacity over the Christmas break, to
cope with volume expected for CLP notifications
(Bob Warner has heard ECHA expects traffic on
REACH-IT 1, 2 or 3 orders of magnitude greater
than REACH pre-reg. – can the system cope?)
• Downside: “REACH-IT is continuously available
during the week from Monday 08:00 to Friday
19:00” (Eastern European Standard Time, GMT +
2, ie GMT 6 am to 5 pm). “REACH-IT will not be
accessible during weekends and public holidays”.
YCF REACH Network meeting, 9th March 2010
11
IUCLID 5-2 available now
• Download from
http://iuclid.echa.europa.eu/
• Mark Selby has provided installation
help notes for stand-alone PCs and
laptops at
http://www.denehurst.co.uk/id33.ht
ml (server copies will be different)
YCF REACH Network meeting, 9th March 2010
12
What’s different for IUCLID 5-2?
• Most important bit - CLP
classification is included
• several updates of the OECD Harmonised
Templates used to report information from
studies on chemicals
• Some plug-ins are now integrated into
IUCLID: bulk export; management of the
Literature References Inventory; backup
plug-in
YCF REACH Network meeting, 9th March 2010
13
Some plug-ins are still external to
IUCLID 5-2
• you need to download these
separately, being released gradually
during March:
– Technical Completeness Check plugin
– Chemical Safety Report plugin
– Query Tool plugin
YCF REACH Network meeting, 9th March 2010
14
Watch out for handover:
• If you have a stand-alone version, the handover
from 5-0 or 5-1 occurs when you download
IUCLID5-2, so there’s no choice
• However, if you have a server, you can still keep
your previous IUCLID5.0 and/or 5.1 versions
(ECHA recommend this to migrate data over
easily)
• This means you have to choose at what point you
migrate - may be tricky if you’re halfway through
a dossier – sooner or later?
YCF REACH Network meeting, 9th March 2010
15
The next REACH-IT upgrade
• REACH-IT is offline for upgrading
from 7pm EET/ 5pm GMT on
Wednesday 17th March
• New REACH-IT goes live on
Monday 22nd March 2010,
9am EET/ 7am GMT
YCF REACH Network meeting, 9th March 2010
16
New REACH-IT – two major
changes
• Accepts dossiers via IUCLID 5-2.
n.b. new REACH-IT is compatible
with IUCLID5-2 ONLY, other versions
can still be used in-house, but won’t
be accepted by REACH-IT
• Can be used for CLP notifications,
separate to REACH late preregistrations
YCF REACH Network meeting, 9th March 2010
17
IMPORTANT POINT
• When you use IUCLID 5-2 and new REACH-IT,
you MUST have your substance classified for CLP
as well as CHIP, otherwise it will NOT PASS
COMPLETENESS CHECKS
• Technically, this brings forward the CLP deadline
for anyone registering from 22nd March onwards
• Otherwise would have meant all the people
registering this summer would have had to
resubmit in December - chaos
YCF REACH Network meeting, 9th March 2010
18
If you are registering from 22nd March
onwards – for LRs & people compiling
dossiers for them
• Make sure you have got your CLP
classifications ready
• If necessary, ensure your company has
bought the upgrade to your Classification
and Labelling Software (or plan to, in
good time before your application goes in)
• Get your 2010 REACH substances
classified for CLP before any other
substances (eg 2013/2018)
YCF REACH Network meeting, 9th March 2010
19
The other major change to
REACH-IT – CLP Notification
• CLP Notification is required for exactly the
same people as REACH, that is
manufacturers and importers, and NOT
downstream users
• The good news is that, if you are fully
registered by 1st December 2010, you will
be deemed to have made CLP notification
for those substances
YCF REACH Network meeting, 9th March 2010
20
And the bad news?
• If you’re part-way through
registration, you should make CLP
notification, as a precaution, in case
you’ve not registered by 1st Dec
2010
• And of course if you’re registering
after 2010, you’ll need to make the
CLP notification anyway
YCF REACH Network meeting, 9th March 2010
21
Not to mention the
usual sting in the tail
• With CLP, there is NO DE MINIMIS, that is
the 1 tonne per year minimum does not
apply
• That’s why ECHA are expecting such a
huge volume of notifications
• It applies to ALL substances, including
those for R&D (although you don’t need to
put data in)
• Will bulk CLP notification be available?
(like bulk pre-registration)
YCF REACH Network meeting, 9th March 2010
22
Companies worst-affected by CLP
notification
• Anyone making in small quantities who’s
avoided REACH so far
• Companies with Registrations after 2010
• Companies with massive bespoke product
ranges
– Laboratory chemical manufacturers
– R&D labs
– Dyestuffs companies
• These are often quite small companies,
may be short on resources
YCF REACH Network meeting, 9th March 2010
23
Responsible Care
• “Provide help and advice to foster the
responsible management of chemicals by
all those who manage and use them along
the product chain”.
• Companies in <1 tonne range may need
informing of requirement – inform your
customers and suppliers (especially R & D
labs and lab chemical suppliers)
• You’re all “experts” now – help smaller
companies with sign-up and how to notify
YCF REACH Network meeting, 9th March 2010
24
CLP notification thoughts
• If you’ve already signed up to REACH-IT
to run REACH pre-registrations (and
registrations), hopefully you won’t need to
sign in again
• Don’t know if there’ll be a link to existing
pre-registrations (too helpful?)
• Until it’s out, we won’t know how it works
– any volunteers to test the system &
report back to YCF Network?
YCF REACH Network meeting, 9th March 2010
25
Getting through CLP notification
• Bulk notification ability will help – if
provided
• If similar to pre-registration, quite
fast to input manually (1 to 2
minutes)
• Best time may be 7am – 9am before
UK wakes up; or 4pm – 5pm once
most of EU finished work
YCF REACH Network meeting, 9th March 2010
26
CLP Notification do’s & don’ts
– Don’t do “pre-emptive” notification if
you’re a Downstream User
– Don’t notify substances not currently on
the market, wait until you make them
again – 1 month deadline to notify
– Do remember to notify for substances
sitting in your warehouse you want to
sell
YCF REACH Network meeting, 9th March 2010
27
Really, really important
• CLP notification will effectively close
before Christmas 2010, so do your
notifications early, as there’s likely to
be a last-minute rush
• Official closing date is 4th January,
but don’t forget Christmas Holidays think of Thursday 23rd December as
last date
YCF REACH Network meeting, 9th March 2010
28
•
•
•
•
Ignore mis-translation of CLP
notification deadline
There has been some info about CLP
Notification opening on 1st December
2010 until 4th January – some people
assumed this is the only time you can
make CLP notification
This is NOT TRUE (it’s the time when you
can only notify for CLP, or Late Pre-reg)
CLP notification is open as soon as the
new upgrade comes through
TTE advice – make CLP notification ASAP
YCF REACH Network meeting, 9th March 2010
29
Speaking of mis-translations
• A colleague has received a notice from
REACH Centrum for Acetic Acid SIEF
saying “currently has no intention to offer
a letter of access other than for Full
registration at > 1000 tes/a/legal entity”
• Panic! Won’t they sell it at smaller tonnage
bands?
• Probable mis-translation/
misunderstanding – currently is the key
word (door is open to offer it later)
YCF REACH Network meeting, 9th March 2010
30
Most immediate CLP issues
1. New labels & MSDSs for product
containers and transport (substances)
2. Awareness and training required for all
staff handling chemicals
– What labels mean
– Reading new-style MSDSs, including new H
and S phrases
3. (Rewrite COSHH assessments and/or
process instructions, and general H&S
Risk assessments)
YCF REACH Network meeting, 9th March 2010
31
CLP Labelling issues
• Use software package, don’t classify
manually
• Traditionally, labels print in black on
coloured “blank” label (cheap!)
• May need colour printer for red diamonds,
unless UK (ie HSE) allow “empty”
diamonds – a lab chemical company have
queried this (apparently can be decided at
country level, so may vary within EU)
YCF REACH Network meeting, 9th March 2010
32
Getting help with CLP training (1)
• Free examples - Merck Poster, Fisher
MSDS, Merck MSDS
• Merck online training
http://www.merck-chemicals.co.uk/isbin/intershop.static/WFS/MerckInternationalSite/Merck/en_US/media_files/ghs_elearni
ng/index.htm
YCF REACH Network meeting, 9th March 2010
33
Getting help with CLP training (2)
• Training eg from REACHReady, the NCEC
etc may be biased towards reclassification,
not practical recognition of symbols and
language, so may need to do this in-house
• For technical queries, HSE are Competent
Authority for CLP/GHS – use the REACH
helpdesk email to contact
[email protected]
YCF REACH Network meeting, 9th March 2010
34
Rewriting risk assessments for
chemical substances
• If your in-house H&S materials use photos
or drawings of CHIP labels, need to
replace with CLP equivalents (possibly side
by side to start with) – needs to match
what people actually see on the new labels
• If use R-phrases, retain these side by side
with new H-phrases during 5 year dual
classification period
• Otherwise update on normal review cycle
YCF REACH Network meeting, 9th March 2010
35
Thank you very much
• Any questions?
• Presentation & information available on
request
• Contact tel 01422 24 22 22
• Email [email protected]
• www.ttenvironmental.co.uk
YCF REACH Network meeting, 9th March 2010
36
Descargar

Slide 1