The Globally Harmonised System (GHS)

The Globally Harmonised System (GHS) for the classification and labelling of chemicals is a United Nations initiative to facilitate international trade in chemicals, to standardise classification according to health, physical and environmental hazards, and to better inform users through standardised material safety data sheets (MSDS).

The Classification, Labelling and Packaging of Substances and Mixtures (CLP) Regulation, which implements GHS in the UK, will be fully in force from 1 June this year.

Most of the responsibility for classifying, packaging and labelling according to CLP rests with chemical suppliers, but end-users must also be aware of the changes and check that all newly purchased chemicals are compliant. The changes were highlighted in the revised COSHH policy:

Supervisors were required to bring the changes to the attention of everyone involved in work with chemicals, and ensure that the requirements of CLP were phased in and fully implemented by 1 June:

To reiterate, the following applies:

(a)     Working stock bottles should now be labelled with the ‘new’ style GHS compliant labels (red diamond frame with black hazard symbol), rather than ‘old’ style pictograms (orange and black diamond). From 1 June 2017 all old hazard warning symbols are invalid.

(b)     Unwanted chemical stock should be safely disposed of (via the hazardous waste disposal route), and for departments with a small chemical inventory any remaining chemical warning labels should be replaced with CLP compliant ones. It would be highly impractical to replace labels in departments holding significant chemical stocks, and there is no requirement to do so, but they should continue to turnover old, unwanted stock and in this way systematically replace any labelled under the old system.

(c)       COSHH assessments must be reviewed and updated to reflect the new Hazard and Precautionary (H&P) Statements. (Note that suppliers are obliged to provide a copy of CLP-compliant MSDS on request). The COSHH review should consider whether any additional control measures are now required under GHS (e.g. the need for health surveillance, or additional control measures), particularly where the ‘old’ risk and safety phrases indicated a lesser severity in effect (e.g. where ‘toxic’ chemicals had previously been classified as ‘harmful’, or where H&P statements now cross multiple hazard classes).

(d)       If the H&P statements require an equivalent or lower level of stringency, existing protocols and SoPs are probably still valid, as new controls may not be required.  However, they should be checked against relevant COSHH assessments and updated to reflect the new H&P statements before 1 June 2017.

(e)       COSHH assessments for all new work must use the information provided in H&P statements as the basis on which control measures are decided.

Heads of department must ensure that these requirements have been met or that significant progress has been made.

The review of COSHH assessments should be included on the agenda of Departmental Safety Advisory Committees and if there are gaps a deadline must be established for their completion.

23 May 2017                                                                                                                           J Black