Update of hazard determination and
communication regulations is a dynamic process that is driven by
developments in technical progress, availability of new data and the desire
to achieve greater harmonisation between systems. The most important recent
changes are summarised as follows:
Commission Regulation (EU) 2015/830
This regulation contains the current version of Annex II to the REACH Regulation. It specifies
detailed requirements for Safety Data Sheets in the European Union,
including the use of mandatory subsection headings. It applies to all SDS issued after the 1st
June 2015 and allows a further two years to
bring existing SDS into compliance with the requirements, which essentially
means removal of information according to the previous classification system.
ADR 2015 Applicable from January 2015
- Instructions in writing revised again!
Updated version not mandatory until July 2017
- Provisions adopted for the transport of adsorbed
- Environmentally hazardous substances UN 3077 &
UN3082 in receptacles ≤ 5 L may be carried exempt from the regulations
- Updated provisions for some wastes -
lithium batteries including damaged batteries, discarded packaging
IMDG Code 2014, mandatory from
- Adopts changes outlined above under ADR, except
for discarded packaging and instructions in writing
- Introduction of codes for stowage, segregation
OSHA HAZCOM 2012
This update of 29 CFR 1910.1200 marks the adoption by the US of the GHS as
the hazard communication standard for the workplace with a transition
deadline of June 2015.
Classification, Packaging, Labelling
Regulation (EC) No 1272/2008
The regulation was published in December 2008 and introduces the UN Globally
Harmonised System for hazard communication. A number of ATPs to the
harmonised classifications have already been published. Manufacturers and importers of
chemicals must notify their classifications of substances to the
Classification and Labelling Inventory, which are published by the European
Chemicals Agency (ECHA) on their website.
REACH Regulation (EC) No 1907/2006
After considerable discussion and negotiation, the final REACH
regulation was published in the Official EU Journal on the 18th December
2006. This requires manufactures and importers to go through a process
- evaluation and
- authorisation of chemicals,
A Fundamental element is that all existing
chemicals being placed on the EU market in excess of 1 Ton per enterprise
per annum must now be registered. Registration requires the submission of the same type of information as was previously only required for notification of new substances
i.e. substances placed on the market after 1981. Responsibility for
registration rests with the Manufacturers of chemical substances in
the EU and Importers who import either substances or products
containing substances from outside the EU. Non-EU manufacturers may
appoint an EU-based Only Representative to prepare registrations on
their behalf, and thus maintain access to EU markets.
Various phase in periods are
allowed, depending on the quantities and hazards involved. Potential
registrants had to Pre-register between 1st June 2008 and 1st
December 2008 in order to avail of the phase-in period and have the
opportunity to share registration costs with other registrants.
Manufacturers/importers new to the market may still avail of the phase in
period for the 1-100 ton bracket under late pre-registration provisions.
A number of materials have been identified as
substances of very high concern (SVHC) and are moving through the regulatory
restriction process which will eventually require granting of specific
authorisations for continued use.