This paper reviews the issues that surround the implementation of the CHIP 3 chemicals packaging regulations.
In September 2001 the Consultative Document (Con. Doc.) "Proposals for the Chemicals (Hazard Information and Packaging for Supply) Regulations 2002: CHIP 3" was published.
CHIP 3 will be welcomed in that it will revoke CHIP 2 and will pull together the multitude of CHIP 2's amendments (of which there are about 7 at present). However, it will also go much further than CHIP 2 and will affect almost all organisations involved in packaging and labelling hazardous goods.
There has already been some excellent work published on the technicalities of the proposals, but this Technical Note provides a brief introduction as to how the changes may affect your organisation and provides some advice on what you should do next.
Will the changes affect you?
Unfortunately the answer is almost certainly "yes", as the scale of the change is quite large.
When will the changes affect you?
The full and final CHIP3 package (Regulation, Approved Supply List, Approved Classification & Labelling Guide and two Approved Codes of Practice: Test Methods & SDS) is not likely to be published until towards the end of May 2002. The Con. Doc. proposes that all transitional arrangements will expire on 30 July 2002. In other words you will have to be compliant with the new regulations by the beginning of August 2002.
What effect on you?
The most significant effect of CHIP3 will be that the classifications of your products may change. This obviously leads to changes to your labels and Safety Data Sheets (SDS). There are also specific changes to the rules on SDS outlined in a new SDS Approved Code of Practice (ACOP).
The main changes
Environmental classification and labelling for preparations
The Con. Doc. describes this as "the major change" of CHIP3. It is major because all substances that have an environmental hazard, and are included in your preparation, have to be included in the "calculation" of the overall hazard of your preparation. Environmental hazard has previously been excluded from the overall hazard classification.
Therefore, you will have to examine each of your preparations and determine if any of the constituents has an environmental hazard. If they do, you need to recalculate the overall hazard to see if your preparation's label will need to carry the "dead fish and tree" symbol as well as any safety and health symbols. If so, you will also need to assign the appropriate R phrases (of which there are many!). Any changes will, of course, need to be carried through to the appropriate sections of your SDS.
Approved supply list
CHIP3 will be accompanied by a completely new Approved Supply List (ASL). The Consultative Document shows 350 new entries, 138 changes and three deletions.
These changes could affect the classifications of your products, leading to amendments to labels and SDS.
Preparations not classified as sensitisers, but that contain small amounts of sensitising substances (0.1% unless there is a specific limit in the ASL) will now have to carry a warning label, clearly indicating the name of the sensitising substance.
You will need to check all your preparations to determine if they contain a small amount of sensitising substance. If this is over 0.1% (or at the limit shown in the ASL for that substance), then you will need to re-label the preparation.
This change could have a large impact on consumer products.
SDS for substances containing small amounts of dangerous substances
This is a new requirement for preparations "not classified as hazardous in their own right, but containing 1% or more (or 0.2% by volume for gases) of: a) a dangerous substance, b) a substance with a community exposure limit."
Suppliers will have to make SDS available for these preparations.
Again, you will have to analyse the constituents of your preparation, check the %, and if applicable, prepare a SDS.
Revision of some labelling phrases
Some of the R & S phrases will change, slightly. You will need to change all labels that carry these phrases.
Plant protection & biocidal products
These products will now have to conform to the full CHIP classification, packing and labelling requirements. (The transitional period for this requirement expires 30 July 2004).
New safety data sheet Approved Code of Practice (ACOP)
As well as the main changes listed above, CHIP3 contains a new ACOP. The changes "seek to improve the accuracy and comprehensibility of SDS to assist users such as workers and small businesses".
Some information that was previously "guidance" has been moved into the ACOP proper, and can, therefore, be interpreted as having moved from "recommendation" to "mandatory". The changes are too wide and varied to be detailed in this Note.
What to do next?
The changes detailed above could have a marked affect on the classification, labelling and SDS of your substances and preparations.
You should therefore familiarise yourselves with the Consultative Document "Proposals for the Chemicals (Hazard Information and Packaging for Supply) Regulations 2002" and carefully analyse the proposals to see how they affect your products. You should also do the same with the full document once it becomes available.This article was produced courtesy of the National Chemical Emergency Centre