CLP: The next step

CLP: The next step

As you may or may not be aware, the next phase of the Global Harmonisation Scheme (GHS) and the classification of hazardous substances has already started. From 1st December, suppliers must classify substances according to both CHIP and CLP, they must be labelled products and packaged including the product’s Material Safety Data Sheet (MSDS) according to CLP. But for mixtures it is slightly different. Suppliers must continue to classify mixtures according to CHIP, and may continue to label and package them according to regulations 6 to 11 of CHIP.
However, they may as an alternative choose to classify, label and package mixtures according to CLP. In this case, they must continue to classify under regulation 4 of CHIP, but the requirements on labelling and packaging in regulations 6 to 11 of CHIP no longer apply. For mixtures the time frames are different, they must continue to carry CHIP labelling until 1st June 2015

So what is the definition of a substance and a mixture according to CLP?

A substance is any material with a definite chemical composition. It’s usually anything which is either a chemical element or compound. The main difference between a mixture and a compound, is that a compound has to have a certain ratio of elements to create a substance where as a mixture does not. For example, Ammonia has to have a certain combination of elements to create it, where as a solvent-based paint does not.

So what will happen if I have a substances and mixtures still in stock with no CLP pictograms?

According to Article 61(4) CLP, if the substance or mixture is classified, labelled and packaged in line with Directive 67/548/EEC (Dangerous Substances Directive, DSD) or in the case of mixtures Directive 1999/45/EC (Dangerous Preparations Directive, DPD) and has already been placed on the market before 1 December 2010 or 1 June 2015 respectively, the substance or mixture which is still in stock does not have to be relabelled and repackaged in accordance with the CLP rules by the supplier until 1 December 2012 or 1 June 2017 respectively.
So in terms of stock that you may already have, there is a 2 year phase out of the old labelling of products before it has to be relabelled. But any substance which is being produced from 1st December, would need to have CLP classification on the label. They may also show CHIP classification.

Will CHIP be totally phased out?

Yes, it will. The aim is to have CHIP labelling phased out by 1st June 2015 (the same date in which CLP pictograms will have to appear on mixtures!!).

So as you can see there are a few transition periods with the migration but you have to remember this is all coming in to force to avoid confusion with other methods of classification and improve chemical safety and occupational safety globally by constructing a suitable and sufficient COSHH risk assessment to protect the most important resource. The employees!

If you need any more advice you can contact us on 01296 380700 or email helpdesk@sypol.com and speak any member of the team who will be happy to help

Rob Wilkes

Completing Assessments Transferred from Version 6

When transferring from CMS 6 to 7, one of the initial problems may be that all of your COSHH assessments which you previously had in CMS 6 will automatically be put into your “incomplete assessments”. The reason being is that the previous system didn’t store the request information. In terms of COSHH, your Exposure Scenario can be classed as you “significant findings” and your COSHH Control Sheet is your “steps to adequately control exposure”. As these are new features on CMS 7, this is the reason that this information hasn’t been captured previously. So at some stage you will need to enter a retrospective scenario so you can start to complete your assessments. Before you start this process you will need to ensure that all the activities you conduct are selected in the Work Area, to do this you will need to go to Work Area > Search for the Assessment > Highlight the Assessment > Click Activities on the bottom half of the Screen > and then you can view the activities and see if they are relevant.

If you know that all is in order, what you will need to do is select My CMS > Incomplete Assessment > Highlight the Assessment > Create Exposure Scenario which is in the bottom half of the screen.


This will take you through to Step 3 of the Request Wizard and you will need to follow the Prompts as per normal. When you have clicked “next” it will take you through to Step 4. The only difference here is with the Activities. Instead of 3 drop down menus giving you the chance to pick different combinations, it will already have the combinations pre-selected for you. You will need to select the activities you need and fill out the Exposure Scenario as normal. Once you have clicked next, the system will automatically ask you if you would like to complete you COSHH Control Sheet

Based on the way in which the material is being used during the chosen exposure scenario, advice will be provided on your requirements under COSHH regulations 7, 10, 11, 12 or 13. These questions will always vary dependant of the initial hazard of the product and whether it is considered requisite or not based on the information inputted into the exposure scenario and the risk of the activity.


The boxes should be ticked to indicate whether you are compliant with these requirements or not, and space is available to attach documentation relating to these requirements. The attachment area is a link to the file location rather than the document itself. Please ensure that this information is on a shared network drive or a drive which is accessible for COSHH coordinators.

If you have any COSHH queries, please feel free to comment leaving contact details or contact Sypol on +44 (0) 1296 380 700 or email us at helpdesk@sypol.com

I hope this helps

Rob Wilkes

British Airways Engineering Family Day a Success

In September, Sypol took part in British Airways Engineering family day, which helped them to raise over £10,000 for Flying Start, British Airways' charity partnership with Comic Relief.

British Airways Engineering, who use CMS, Sypol's COSHH Management System, welcomed more than 10,000 colleagues, family members, friends and invited guests over the weekend at the end of September.

Sypol were delighted to take part in the weekend activities, and provided giveaways to raise money for the charity, whilst showing its range of health and safety services. There were some really interesting and interactive exhibits that were enjoyed by adults and children alike, and this event was very well organised by British Airways Engineering.

We look forward to taking part again next year.

Sypol engagement

We are pleased to announce that Zoe Rowe, one of our CMS administrators yesterday became engaged to James Barnes, on of our occupational hygiene consultants. We wish them every happiness for the future.

CMS testimonial

Watch our latest video testimonial from Elwyn Harker of Barnet & Chase Farm Hospital, talking about his experiences using CMS from Sypol.

Vacancy

We are looking for a graduate interested in occupational hygiene.
Click here for more information

We are here for you

A great many things are automated these days, bypassing the need for human intervention entirely.
So its comforting to know that when you plug all that information into the CMS 7 software, it goes straight to a real live qualified Sypol consultant who then puts together your COSHH assessment for you.

Here is are some of them. Friendly bunch aren't they?

Not only that, they are on the end of the Helpdesk (01296 380700, or helpdesk@sypol.com) waiting to assist with your queries on the CMS software, or indeed any topic, including their favourite chocolate biscuit - because your consultants certainly love to eat.

So call us for a chat and brighten our day.

Updates to CMS 7 software

You'll be pleased to hear that a number of new items have been added to the CMS 7 management software and these will be active from Thursday 8th July and are shown below:

Printing
You will see additonal printing options. For complete assessments you can now print any of the following:

• COSHH Summary Sheet
• Exposure Scenario
• COSHH Control Sheet

My CMS dashboard
The My CMS summary screen now has a new graph showing the percentage of coshh control sheets completed.

Account settings
You will now be able to add telephone numbers, email address and fax numbers to individual user account settings.

Exposure scenario
A new question is being added to the exposure scenario about whether the material is being used outside of the normal temperature range

If you need help with these or any other changes to your CMS, give the team a call on the helpdesk or email helpdesk@sypol.com.

Getting ready for CLP

The CMS consultants have been getting to grips with hazard classification of substances under the CLP Regulations, and all the delightful new pictograms which will be coming to a product label (and Sypol COSHH assessment) near you from December this year.

http://www.hse.gov.uk/ghs/eureg.htm

Some of the symbols are slightly bizarre and will take a bit of getting used to, but its all in the name of progress.

In this joyful transition period (until June 2015), statements like the one below are cunningly designed to pull you up short on a Monday morning after a heavy weekend following the World Cup:

20th January 2009 – 1st December 2010: Suppliers must classify substances according to CHIP, and may continue to label and package them according to regulations 6 to 11 of CHIP. However they may as an alternative choose to classify, label and package substances according to CLP. In this case, they must in addition continue to classify under regulation 4 of CHIP, but the requirements on labelling and packaging in regulations 6 to 11 of CHIP no longer apply.

Never fear, we have chemists at Sypol who, despite being massive football fans, are not phased by this sort of language, and are happy to explain it in simple terms at half time to anyone who will listen.

The competent smell of roses

Competence is an adjective rarely used as a form of praise in the world outside of health and safety.

Helen of Troy’s competence never launched a single ship; the leader of the Macedonians was not Alexander the Competent and a rose by any other name would not smell as competent.

In the wider world, competence is an adjective that describes the middle ground. It describes base mediocrity, a dull compliance with what people expect and the minimum standards for inclusion.

You would be deeply disappointed if you attended a competent performance at the Royal Opera House, followed by a competent meal at the Savoy Grill.

However, in our field, competence is an adjective that puts people in the highest bracket of those we would put our trust, our health and our company’s prosperity in the hands of. Competence in this case is a knowledge and acceptance of responsibility; an innate or learnt ability and a safe pair of hands.

Competence is a mixture of qualities. Skill, knowledge, intelligence and experience all go into the blend, but the blend has to be right for the circumstances. I would happily let Richard Dawkins run my genetics laboratory; I would not let him replace my central heating.

Do I really need a COSHH assessment for water?

Are you struggling to get your head around COSHH? After all, you need a degree in chemistry to get to grips with all these chemicals right?

Even if you are quite comfortable with the Safety side of Health and Safety, the Health bit can be pretty daunting.

If you’re not careful, one of two things can happen; you stick your head in the sand and hope it will go away (after all, you’re far too busy with the safety stuff). Or you go the bonkers conkers route, spend hours assessing things which you don’t need to, and the whole thing loses credibility.

Both options spell disaster.

You need to:

• Get proper training and support from people who know what they’re talking about when it comes to the COSHH regulations.

• Decide whether you are going to do the assessments yourself. If not, find a reputable organisation with the competency to put them together for you.

• Manage COSHH properly, in the same way you manage other risks to your business.

So, do you need a COSHH assessment for water?

What do you think? Join the debate - have a rant.