Mariana Mihalcea Udrea NATIONAL ENVIRONMEMTAL PROTECTION AGENCY PACKAGING Mariana Mihalcea Udrea NATIONAL ENVIRONMEMTAL PROTECTION AGENCY BUCHAREST, SPLAIUL INDEPENDENTEI, 294, ROMANIA +4021 202 47 91 +40 746 248 466 m.mihalcea@anpm.ro 22.04.2017

Packaging requirements the packaging is designed, constructed and fastened so that the contents cannot escape; the materials of the packaging and fastening are not damaged by the contents and are not liable to form hazardous compounds with the contents; the packaging and fastenings are strong and solid throughout to ensure that they will not loosen; packaging fitted with replaceable fastening devices is designed to be refastened repeatedly without the contents escaping; the packaging does not attract or arouse the curiosity of children or mislead the consumer when supplied to the general public. NATIONAL ENVIRONMEMTAL PROTECTION AGENCY 22.04.2017

NATIONAL ENVIRONMEMTAL Packaging ‘Packaging’ means one or more receptacles and any other components or materials necessary for the receptacles to perform their containment and other safety functions; ‘intermediate packaging’ means packaging placed between inner packaging, or articles, and outer packaging. NATIONAL ENVIRONMEMTAL PROTECTION AGENCY 22.04.2017

Packaging requirements Packaging containing a hazardous substance or a mixture supplied to the general public shall: not have either a shape or design likely to attract or arouse the active curiosity of children or to mislead consumers, or have a similar presentation or a design used for foodstuff or animal feeding stuff or medicinal or cosmetic products, which would mislead consumers. NATIONAL ENVIRONMEMTAL PROTECTION AGENCY 22.04.2017

Packaging requirements Packaging to be fitted with child-resistant fastenings. Packaging of whatever capacity containing a substance or mixture supplied to the general public and : classified for acute toxicity, categories 1 to 3, STOT — single exposure category 1, STOT — repeated exposure category 1, or skin corrosion category presenting an aspiration hazard and classified and labelled with the exception of substances and mixtures placed on the market in the form of aerosols or in a container fitted with a sealed spray attachment NATIONAL ENVIRONMEMTAL PROTECTION AGENCY 22.04.2017

NATIONAL ENVIRONMEMTAL PROTECTION AGENCY 22.04.2017

Packaging requirements Packaging to be fitted with child-resistant fastenings. Packaging of whatever capacity containing a substance or mixture supplied to the general public and : has at least one of the substances mentioned below present in a concentration equal to or greater than the maximum individual concentrations specified NATIONAL ENVIRONMEMTAL PROTECTION AGENCY 22.04.2017

NATIONAL ENVIRONMEMTAL PROTECTION AGENCY 22.04.2017

Packaging requirements Packaging to be fitted with child-resistant fastenings. Re-closable packages shall comply with EN ISO standard 8317 as amended relating to ‘Child-resistant packages — Requirements and methods of testing for re- closable packages’ adopted by the European Committee for standardisation (CEN) and the International Standard Organisation (ISO). Non-reclosable packages shall comply with CEN standard EN 862 as amended relating to ‘Packaging — Child- resistant packaging — Requirements and testing procedures for non- re-closable packages for non-pharmaceutical products’ adopted by the European Committee for Standardisation (CEN). NATIONAL ENVIRONMEMTAL PROTECTION AGENCY 22.04.2017

Packaging requirements Packaging to be fitted with a tactile warning of danger of whatever capacity Where substances or mixtures are supplied to the general public and classified for acute toxicity, skin corrosion, germ cell mutagenicity category 2, carcinogenicity category 2, reproductive toxicity category 2, respiratory sensitisation, or Stot, categories 1 and 2, aspiration hazard, or flammable gases, liquids and solids in categories 1 and 2, the packaging, NATIONAL ENVIRONMEMTAL PROTECTION AGENCY 22.04.2017

Packaging requirements Provisions relating to tactile warning does not apply to: aerosols which are only classified and labelled as ‘flammable aerosols, Category 1’ or ‘flammable aerosols, Category 2’ transportable gas receptacles. The technical specifications for tactile warning devices shall conform to EN ISO standard 11683 as amended ‘Packaging — Tactile warnings of danger-Requirements’. NATIONAL ENVIRONMEMTAL PROTECTION AGENCY 22.04.2017

Packaging requirements The packaging of substances and mixtures shall be deemed to satisfy the requirements of CLP labelling if it complies with the requirements of the rules on the transport of dangerous goods by air, sea, road, rail or inland waterways. NATIONAL ENVIRONMEMTAL PROTECTION AGENCY 22.04.2017

NATIONAL ENVIRONMEMTAL Packaging The plastic container is not designed and constructed in a way that the contents cannot escape not packaging (Article 35(1)a) The purpose of the object is to let the contents escape! The container should thus have its own packaging, e.g. a plastic bag or a cardboard box, which must be labelled. NATIONAL ENVIRONMEMTAL PROTECTION AGENCY 22.04.2017

Outer & Inner packaging Classified for transport & supply Article 33 (1) This shows article 33 (1) where there is an inner and outer package. The rule for transport and supply both apply. On the inner BOX you can clearly see the application of CLP with the GHS flame pictogram and label elements etc. These two containers are placed in outer packaging for transport and you can clearly see here that only the transport rules apply to the outer box so in this example the flammable picotgram for transport is used. NEXT SLIDE Product identifier Signal word Hazard statements Precautionary statements Contact details Product identifier Signal word Hazard statements Precautionary statements Contact details NATIONAL ENVIRONMEMTAL PROTECTION AGENCY 22.04.2017

Outer & Inner packaging Classified for supply only Article 33 (2) This example shows you the same type of packaging both inner and outer, however in this example the product is not classifed for transport so the rules for CLP are applied both to the inner and to the outer packaging. This is an important NEW RULE as before in this scenario the outer box would have been left blank as the transport rules did not apply so no one was aware that the box contained a hazardous substance. This is therefore a big improvement from a hazard communication perspective but it will require a new module being added to the DSGA course to alert those retraining for those with responsibility for transport hazard communication as they will now start seeing hazardous products appearing in their ‘goods inwards’ and wonder what its all about. that these new outer ‘supply’ labels shall now appear on the outer packaging Product identifier Signal word Hazard statements Precautionary statements Contact details Product identiifier Signal wordHazard statements Precautionary statements Contact details Product identifier Signal word Hazard statements Precautionary statements Contact details NATIONAL ENVIRONMEMTAL PROTECTION AGENCY 22.04.2017

NATIONAL ENVIRONMEMTAL Single packaging Article 33 (3) Classified for supply & transport Thirdly Article 33 ( 3) depicts a single package that is classified for both transport and supply, the rules which allows the CLP hazard pictogram to be ommitted when the transport pictogram for the same hazard applies is shown here, so you can see the transport red pictogram and the text underneath is the CLP supply label elements. If this rule was not applied then you would simply have a separate flame symbol for both supply and transport but you might agree this is both expensive and costly. Next is an example in more ‘real terms’ of how this Article 33 (3) would be applied to say a 200L drum ..here it is NEXT SLIDE Product identifier Signal w ord Hazard statements Precautionary statements Contact details NATIONAL ENVIRONMEMTAL PROTECTION AGENCY 22.04.2017

NATIONAL ENVIRONMEMTAL Article 33(1) For Transport the hazard communication on ‘outer packaging’ is clear NATIONAL ENVIRONMEMTAL PROTECTION AGENCY 22.04.2017

NATIONAL ENVIRONMEMTAL Article 33 (1) For Transport the hazard communication on ‘outer packaging’ is clear Incl. limited quantities NATIONAL ENVIRONMEMTAL PROTECTION AGENCY 22.04.2017

NATIONAL ENVIRONMEMTAL Packaging the outer packaging is not required to meet labelling provisions in accordance with rules on the transport of dangerous goods, so both the outer and any inner packaging, including intermediate packaging, shall be labelled in accordance with CLP. if the outer packaging permits the inner or intermediate packaging labelling to be clearly seen, the outer packaging need not be labelled NATIONAL ENVIRONMEMTAL PROTECTION AGENCY 22.04.2017

Thank you for attention ! 22.04.2017