Europe
Smith, regulatory affairs director at the
British Coatings Federation (BCF).
Classifying of the hazards of mixtures
is mainly done on the basis of the dangers posed by their individual substances,
whose safety profile can change.
The EU’s REACH legislation, on the
registration, evaluation and authorization of around 30,000 substances over
11 years to 2018, is triggering changes in
CLP classifications. At the same time the
scope of what is categorized as a hazard
has been extended.
The CLP regulation has not only introduced new hazard pictograms but altered their design from black symbols on
an orange background to ones on a white
background with a red border. Among the
new symbols is one for respiratory hazards
showing the dark outline of a man with
what looks like an exploding chest.
Mixtures containing solvents now
have to carry a pictogram with a flames
symbol to show the danger of flammability. The application of a symbol of a
skull and crossbones has been extended
to cover a broader range of danger.
“Customers and their staff working
in manufacturing, as well as profession-
al decorative painters, will know these
symbols because they are already known
in industry and transport,” explained
Michael Bross, director of the German
Paint and Printing Ink Association (VdL).
“But it will be different with consumers.
They will be confused and could be ask-
ing a lot of questions.”
Also customers, both in industry
and the DIY sector, may be surprised
to see hazard pictograms on coatings
products that previously did not carry
them. “Some are quite dramatic look-
ing, ” said Jo Lloyd, technical director at
ReachReady, a London-based consultan-
cy. “There will be purchasers of coatings
and other mixtures who may switch to
another product even though the actual
information in the safety data sheet will
be unchanged.”
Some people in the coatings indus-
try are annoyed that neither the EU nor
national governments and agencies have
launched publicity campaigns to inform
users of coatings and other mixtures
about CLP.
“Compliance with CLP is costing the
coatings industry a lot of money because
companies have had to invest, for ex-
ample, in new software, assistance from
consultants and training,” said Smith.
“Many end-users will not fully under-
stand what CLP is all about and with
them all the work put into implementa-
tion of the regulation could turn out to be
a waste of money.”
Parts of the regulation, which has al-
ready been subject to a number of correc-
tions and additions since it was approved,
now looks likely to be changed after the
European Commission decided to ask
representatives of national health and
safety agencies to sort out certain prob-
lems with the CLP rules.
A major difficulty has been a lack
of clarity in the text of the regulation
on the question of multi-lingual folded
labels used on small packs and containers of speciality coatings and other
products. There are also claimed to be
ambiguities on the subject in the guidance on the regulation issued by the
European Chemicals Agency (ECHA),
the EU body based in Helsinki, Finland,
which administers the CLP, as well as
the REACH legislation.
EU member states have taken advantage of the uncertainties to impose restrictions on the use on small packs of
multi-lingual folded labels language, including a provision that a warning in the
language of each domestic market must
be listed first.
“With a folded multi-lingual label
manufacturers of speciality coatings
products have been able to use a single
label for the whole of Europe,” explained
Bross. “If the national language of each
country has to come first a different label
will have to be provided for each country.
That will be expensive and a barrier to
free trade.”
The labeling of coatings with bio-
cides could also be an issue because the
implementation the EU’s new Biocides
Products Regulation (BPR) has yet to be
completed. Safety assessments of bio-
cides under the BPR are still being car-
ried out particularly at the national level.
“There are also still uncertainties
whether the hazard classification of
a biocide under the BPR should be
incorporated into the CLP scheme
or should be carried as a separate
warning on the label,” said Janice
Robinson, director product regulations at the European Council of the
Paint, Printing Inks and Artists Colour
Industry (CEPE), Brussels.
The CLP rules are closely aligned to
those laid down in the United Nations’
Globally Harmonised System (GHS) of
classification and labelling of chemicals.
So any GHS changes will have to be included in the CLP regulation.
To keep up with research into the safety features of substances and mixtures,
the CLP regulation was drawn up so that
alterations to classifications can be made
to allow for what is called ‘adaptation to
technical progress’ (ATPs).
Mixtures, particularly the interaction
between substances within them, are a
relatively new area of safety research.
The Commission has recently set up a
working group to investigate technological aspects of the safety of mixtures.
“We are in the early days of these sort
of research initiatives so it is uncertain
what will be their impacts on CLP classifications,” said Robinson.
For coatings producers CLP compliance will not just be a matter of meeting deadlines. It will be a continuous
process of ensuring that the hazards
classification and labelling of their
products remains consistent with the
latest safety studies. CW
“If the national
language of each
country has to come
first a different label
will have to be
provided for each
country. ”
