Classification & Labeling of Chemical Substances & Mixtures

The CLP Regulation (EC) No 1272/2008 implements the UN Globally Harmonised System (GHS) for chemical hazard classification in the EU, replacing the old Dangerous Substances Directive and Dangerous Preparations Directive. Under the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH 1907/2006), the Biocides Regulation (528/2012) and the Plant Protection Products Regulation (1107/2009), the vast majority of chemicals (excluding pharmaceuticals) are now assessed for classification under the CLP Regulation in Europe.

CLP came into force on January 20, 2009. Starting December 1, 2010, all substances must be classified and labelled in line with CLP. Starting June 1, 2015, all mixtures must be classified and labelled in line with CLP. Mixtures already classified, labelled and packaged in line with the Dangerous Preparations Directive (DPD) and already on the market will need to be relabelled and repackaged by June 1, 2017.

In the EU, Exponent can help clients ensure compliance with CLP by reviewing available data to determine classification and labelling for a substance, identifying where additional information may be required and developing data collection strategies and are also able to derive the appropriate classification and labelling for complex mixtures. Exponent can also advise on strategies for dealing with severe classifications such as carcinogenicity and with the preparation of CLH dossiers for harmonised classification and labelling and providing support at technical committees considering proposed harmonised classifications.

United States

On May 25, 2012, United States Occupational Health and Safety Administration (OSHA) updated 29 CFR 1910.1200 Hazard Communication Standard (HazCom 2012). HazCom 2012 implements GHS for chemical hazard classification in the US. The deadline for compliance in the US was June 1, 2015, with GHS classifications being accepted during this transitional period. HazCom 2012 also included deadlines for the initial training of workers on GHS and the new Safety Data Sheet format by December 1, 2013 and the updating of workplace hazard communication programs by June 1, 2016.

In the US, the implementation of HazCom 2012 will result in new classifications for existing substances and mixtures compared to that of HazCom 1994. HazCom 2012 is applicable to Safety Data Sheets for both industrial chemicals regulated under the Toxic Substances Control Act (TSCA) and those products regulated under the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA). In the US, Exponent can help clients prepare for HazCom 2012 by providing classification comparisons with the previous OSHA HazCom 1994 as well as assisting in the compliance for FIFRA regulated products. Weight of Evidence evaluations can also be conducted for establishing the classifications for carcinogenicity, mutagenicity, germ cell mutagenicity and target organ toxicity.