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Dr Colin Hewlett DGSA consultant
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Chemicals
and Transport Limited
Supply – CHIP4 Regulations – Chemical (Information and Packaging for
Supply) Regulations 2009 CHIP4
which came into effect on 6 April 2009 consolidates CHIP3 and subsequent
amendments; it continues to implement the EU Dangerous Preparations Directive
and the Dangerous Substances Directive as an interim measure before REACH and
CLP come into full force. The approved Classification and Labelling Guide
(ACLG 6th edition) has been issued as a supporting document to
CHIP4 but the Approved Supply List has not been re-issued as its provisions
are now included in the EU CLP Regulations. CHIP4 does not specifically
regulate Safety Data Sheets since the Safety Data Sheets Directive has now
been repealed and its measures incorporated into the REACH Regulations. The REACH
regulations (Registration, Evaluation and Authorisation
of Chemicals) which came into law (direct acting EU regulation) in
June 2007 have superseded the Safety Data Sheet requirements of CHIP. REACH
came fully into effect in June 2008
when the first stage of pre-registration of chemicals began. REACH timetable: o
Pre-registration of phase-in substances:
1 June - 1 December 2008 o
Potential registrants who for the first
time manufacture or import a phase-in substance in a quantity of ≥1 tpy after the pre-registration deadline (later than 1
December 2008) may submit a pre-registration dossier within six months of
first manufacturing or importing or using the substance and no later than 12
months before the relevant registration deadline o
Registration of substances that have
been pre-registered, all substances supplied at ≥1000 tpy; ≥100 tpy R50/53
substances and ≥1tpy class 1 and 2 CMRs
before 1st December 2010 o
Information on classification and
labelling of all substances subject to registration or classified as
hazardous submitted to ECHA for inclusion on inventory: 1st
December 2010 o
Registration of substances that have
been pre-registered, tonnage 100-1000 tpy before 1
June 2013 o
Registration of substances that have
been pre-registered, tonnage 1-100 tpy before 1
June 2018 o
Substances which have not previously
been placed on the EU market (non-phase-in substances) and phase-in substances which have not
been pre-registered must be registered before manufacture or import. By
means of the CLP (Classification Packaging and Labelling) Regulations
implements GHS (global harmonisation system of classification &
labelling) The CLP regulations (EC) No 1272/2008 on
the Classification, Labelling and Packaging of chemical substances and
mixtures, which implements the UN Globally Harmonised System (GHS) at EU
level, entered into force on 20 January 2009. The deadlines for implementing
the new system are 1 December 2010 for substances (coinciding with the first
registration deadline for phase-in substances), and 1 June 2015 for mixtures. The
CLP Regulation will gradually replace the current rules of Directives
67/548/EEC for dangerous substances (DSD) and 1999/45/EC for preparations
(DPD) as implemented by the CHIP regulations in the UK (CHIP4) during a
transition period ending on 1 June 2015, when both Directives will be
definitively repealed. The
transfer of Annex I entries to Annex VI did not include the 30th and 31st
amendments to technical progress (ATP) of the DSD, which were adopted before
the entry into force of the CLP Regulation but this has now been accommodated
with the publication in August 2009 of the first ATP to the CLP Regulation
(EC) 790/2009 (enforceable from 1st December 2010). CLP
deleted Title XI of REACH on the “classification and labelling inventory” and
transferred an amended version of these provisions under Chapter 2 of Title V
of the CLP Regulation itself. The obligation to notify the new CLP
classification and labelling of substances by 1 December 2010 also applies to
all substances placed on the EU market that are classified as “dangerous”
(“hazardous” under the CLP), not only those that require registration by that
date. This applies to all manufacturers and importers of dangerous substances
including those present as components in mixtures whatever the volume so a
substance can be subject to notification for the C&L Inventory even if
exempted from registration under REACH. GHS The Globally
Harmonised System of Classification and Labelling of Chemicals (GHS) aims to
provide a framework to bring together the various national and regional
hazard communication systems which control the supply of hazardous chemicals in much the
same way that the ‘Orange Book’ offers a global framework for the transport
of dangerous goods. The purpose of GHS is to provide a single globally harmonized system
to address classification of chemicals, labels, and safety data sheets.The first
edition of GHS was published in July 2003 as the ‘Purple Book’ and revisions
published bi-annually.
Last updated: November 2010 |
