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How might the CLP limits affect you?

06 April 2016

Steve Bailey explains how the new CLP regulations might impact food manufacturers – from the perspective of the cleaning fluids used and the way they are disposed. 

European Regulation (EC) No 1272/2008 on the classification, labelling and packaging of substances and mixtures – better known as CLP – came into force early in 2009. June 2015 was the cut-off date by which time all new chemical substances and mixtures, for example, cleaning fluids, needed to be labelled and hazards indicated according to the new CLP criteria. For food manufacturers, this may impact upon both the cleaning fluids they use and the dilution at which they use them – as well as the way in which they are disposed.

The CLP has been designed to incorporate the United Nations' Globally Harmonised System (GHS) on the classification and labelling of chemicals, in a uniform fashion across Europe, with the intention of improving workers' safety worldwide. From 2015, the CLP has become directly applied to all EU member states, including the UK, and is legally binding.

A small number of chemicals are excluded from CLP because they are deemed to be in a finished state as intended for use. This group includes food and ingredients such as food additives, food flavourings and feeding stuffs used in animal nutrition. However food manufacturers still need to be aware of, and understand, the new requirements.

While responsibility for labelling substances and mixtures lies primarily with the manufacturers, importers and downstream users of chemicals, it also affects food manufacturers who use substances and mixtures in their work, and/or in the maintenance of their premises, including cleaning operations. For these groups, there are two key elements to be aware of:

1. The new classifications and safety data used by CLP may trigger a legal requirement for employers and others to revise their health and safety requirements, including risk assessments and the provision of personal protective equipment (PPE).
2. Users of mixtures, including substances that are diluted (many cleaning substances fall into this group) must be aware of the new cut-off limits, generic concentration limits (GCLs) and specific concentration limits (SCLs) that apply to these. It may also be important to consider multiplication factors (m-factors) where substances may be hazardous to the aquatic environment.

Responsibility to employees
The change to CLP triggers several duties in employers; these arise not only under standard health and safety legislation, but also under a range of legally-binding directives designed to protect vulnerable groups. Thus, employers must:

•Identify hazardous chemicals.
•Substitute hazardous chemicals with less hazardous alternatives where possible
•Risk assess the level, type and duration of exposure to hazardous chemicals and substances. •Ensure the safe use, handling, storage and transport of substances.
•Establish appropriate emergency plans and procedures.
•Give employees information, instruction and training concerning hazardous substances. •Carry out monitoring and health surveillance.
•Keep appropriate records.
•Provide appropriate PPE and maintain protective equipment.

This is important because under CLP the classification of a substance as hazardous may now change. This may be because CLP incorporates newly-identified hazard information which means the substance is more or less hazardous than was previously thought, or because hazard data is the same but CLP criteria result in a different classification. Alternatively, a mixture may have been reformulated, using different component substances that have different hazards.

Indeed, it is to be expected that some manufacturers of chemicals and detergents will decide to change formulations because CLP may have re-classified their previous formulation for any of the reasons above, and it will be in their interests to change in order to 'downgrade' that hazard classification. This may, in turn, mean that employers have to run another risk assessment of, or take other action concerning that substance in order to maintain their compliance with employee safety legislation. For example, a change of solvent in a mixture may mean that the employer needs to provide a different form of PPE, or may need to adjust the equipment used to assess airborne concentrations of that solvent.

Understanding the new labels
One of the most noticeable changes is the introduction of new hazard symbols and safety wording on product labels. The black and orange squares found on old labelling will be replaced by new red-bordered diamonds, while some products that previously had no hazard symbol may now feature a hazard diamond due to the introduction of two new pictograms.

While most of the new symbols are similar to the old ones barring shape and colour, the introduction of two new pictograms allows for more stringent CLP regulations and new classifications. This means products which didn’t have a hazard label before may now bear one despite not changing its formula, meaning manufacturers can be more aware of the potential dangers of using certain products.

In addition to the two new pictograms, the old black St Andrew’s cross symbol will be phased out and replaced with three new symbols, while old warning indications, such as ‘corrosive’, ‘irritant’ and ‘harmful’, will be replaced with two new signal words: ‘danger’ – to indicate a more severe hazard – and ‘warning’ – for less severe hazards.

Mixtures and dilutions
Less well-regulated cleaning operatives may be tempted to take 'short cuts' with cleaning substances and this may now leave employers vulnerable under a combination of health and safety and employee protection legislation, and CLP. For example, many factories only have hot water during the day, and out-of-hours cleaners may be tempted to use stronger concentrations than they need in order to compensate for the use of cold water only. There may be a temptation to use stronger concentrations to minimise the need for 'elbow grease', and in other cases unfamiliarity with the legislation may lead to the use of incorrect or too-hazardous chemical.

Even where cleaners are not employed directly by the end user, hazards can remain. Insufficient rinsing or inappropriate use may leave hazardous substances behind on surfaces or equipment, and pose a contamination threat and/or a threat to the safety of employees who subsequently use them, or to end users of the product. These are, of course, very much the business of the food manufacturer.

In many sectors, but particularly in food preparation and manufacture, hygiene and cleanliness needs to reach the highest standards. This is simply not negotiable, and the advent of CLP introduces new duties and requirements that some employers may find onerous. There is, of course, a simple solution to the obligations created by CLP, and that is to work with an experienced cleaning contractor that has a thorough understanding of all matters related to the new directive.

Steve Bailey is managing director of Hygiene Group, a specialist cleaning contractor.

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