CLP/REACH Update YCF REACH Network Meeting Syngenta Huddersfield, 9 th March 2010 Janet Murfin

YCF REACH Network meeting, 9th March 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 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 ….how labels may look (a).. Immediate low level health hazard Long term low level health hazard Compressed gas Replacing Harmful, X symbol Still have Toxic symbol for substances which seriously affect human health New symbol

YCF REACH Network meeting, 9th March Spot the difference – CHIP label

YCF REACH Network meeting, 9th March Chloroform label - CLP/GHS

YCF REACH Network meeting, 9th March Poster shows threshold differences- (free download from Merck)

YCF REACH Network meeting, 9th March CLP and CHIP timelines Now to 1/12/10 1/12/10 1/6/13 1/6/13 – 1/6/15 1/6/15 – 1/6/18 1/6/18 onward Substa- nces CLP optional CLP and CHIP both mandatory CLP implemented in full, CHIP gone MixturesN/aCHIP mandatory CLP optional 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 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 Important point for all REACH registrants – 1 st ATP to CLP Reclassifications coming into force 1 st Dec 2010 may bring forward REACH deadline Available at lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2009:235:00 01:0439:EN:PDF 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 other pre-SIEF/SIEF members

YCF REACH Network meeting, 9th March 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 IUCLID 5-2 available now Download from Mark Selby has provided installation help notes for stand-alone PCs and laptops at ml (server copies will be different) ml

YCF REACH Network meeting, 9th March 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 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 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 The next REACH-IT upgrade REACH-IT is offline for upgrading from 7pm EET/ 5pm GMT on Wednesday 17 th March New REACH-IT goes live on Monday 22 nd March 2010, 9am EET/ 7am GMT

YCF REACH Network meeting, 9th March 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 pre- registrations

YCF REACH Network meeting, 9th March 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 22 nd 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 If you are registering from 22 nd 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 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 1 st December 2010, you will be deemed to have made CLP notification for those substances

YCF REACH Network meeting, 9th March 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 1 st 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 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 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 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 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 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 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 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 4 th January, but don’t forget Christmas Holidays - think of Thursday 23rd December as last date

YCF REACH Network meeting, 9th March Ignore mis-translation of CLP notification deadline There has been some info about CLP Notification opening on 1 st December 2010 until 4 th 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 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 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 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 Getting help with CLP training (1) Free examples - Merck Poster, Fisher MSDS, Merck MSDS Merck online training bin/intershop.static/WFS/Merck- International- Site/Merck/en_US/media_files/ghs_elearni ng/index.htm bin/intershop.static/WFS/Merck- International- Site/Merck/en_US/media_files/ghs_elearni ng/index.htm

YCF REACH Network meeting, 9th March 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 to contact

YCF REACH Network meeting, 9th March 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 Thank you very much Any questions? Presentation & information available on request Contact tel