IB2 Flashcards
Countries in the United Nations, including those in the European Union, have been working together with industry representatives and others to agree a classification and labelling system that can be used worldwide. The outcome is
The Globally Harmonised System of Classification and Labelling of Chemicals, known as the ‘GHS’. The GHS provides a single system to identify hazards and to communicate them in transporting and supplying chemicals across the world i.e. label and safety data sheets
European Union (EU) Member States agreed to adopt the GHS across the EU through a direct acting Regulation
The Classification, Labelling and Packaging of Substances and Mixtures. This is also known as the ‘CLP Regulation’ or just ‘CLP’
In addition to CLP the European Commission presented a proposal for a new EU regulatory system for chemicals
REACH, which stands for: Registration Evaluation Authorisation of Chemicals
All chemicals will require EU authorisation by ________ before the materials are allowed to be sold or imported within the EU. Their use may also be restricted
the European Chemical Agency (ECHA)
REACH is an EU Regulation that covers all chemicals (with a few exceptions) if they are manufactured or imported into the EU in quantities of _________
1 tonne or above
REACH is designed to
Improve information in the supply chain - many substances are data poor and this can lead to inadequate risk assessments.
Promote better risk management measures.
Facilitate compliance with CoSHH.
Encourage the use of safer alternatives for CMR substances.
Allow the free movement of substances on the EU market.
Question the need for animal testing.
Lead to improvements in Occupational health.
Under REACH, each producer and importer of chemicals in volumes of 1 tonne or more per year will have to register each chemical with the EU Chemicals Agency (ECHA), submitting information on:
The general technical, commercial and administrative information needed for all registrations is
specified in Annex VI of the REACH Regulation. This includes the following key information:
1) General information on the registrant
2) Identification of the substance
3) Information on the manufacture and use(s) of the substance
4) Classification and labelling of the substance
5) Guidance on safe use
6) Exposure information for substances in quantities of 1 to 10 tonnes.
CMR
CMRs are substances classified as Carcinogenic, Mutagenic or toxic to Reproduction, category 1 or 2, in accordance with
Directive 67/548/EEC. (‘Classified in accordance with Directive 67/548/EEC’ refers to substances listed in Annex VI of
the CLP Regulation with a harmonised classification and labelling and substances self-classified by the registrant).
Through REACH evaluation, public authorities will look in more detail at registration dossiers and at substances of concern
Completeness check
Compliance check
Dossier evaluation
Substance evaluation
Under REACH, the authorisation procedure aims to assure that the risks from Substances of Very High Concern are properly controlled and that these substances are progressively replaced by suitable alternatives while ensuring the good functioning of the EU internal market.
Substances with the following hazard properties may be identified as Substances of Very High Concern (SVHCs):
Substances meeting the criteria for classification as carcinogenic, mutagenic or toxic for reproduction
Substances which are persistent, bioaccumulative and toxic (PBT) or very persistent and very bioaccumulative (vPvB)
Substances identified on a case-by-case basis, for which there is scientific evidence of probable serious effects that cause an equivalent level of concern as with CMR or PBT/vPvB substances
A comparison between the approach of REACH and CoSHH
Although REACH places responsibility for the identification and assessment of chemical hazards and risks on those ultimately responsible for their manufacture or importation into the EU, this does not change the responsibility COSHH places on employers for assessing risks and deciding how to control them in the individual workplace. This means downstream users are now faced with two sets of obligations under REACH and COSHH.
The intention of the CLP Regulation is
before placing chemicals on the market, the industry must establish the potential risks to human health and the environment of such substances and mixtures, they should be classified, labelled and packaged appropriately. But because CLP adopts CHS, in time, the same classifications and labelling will be used throughout the world.
CHIP is a set of UK Regulations that
was were revoked from 1 June 2015 and no longer have legal effect. Chemical suppliers should comply with the CLP Regulation.
COSHH Regulations 2002 Amended by (The Classification, Labelling and Packaging of Chemicals
(Amendments to Secondary Legislation) Regulations 2015) defines a substance hazardous to health” means a substance (including a mixture) as
(a) which meets the criteria for classification as hazardous within any health hazard class laid down in the CLP Regulation whether or not the substance is classified under that Regulation
(b) for which the Health and Safety Commission has approved a maximum exposure limit or an occupational exposure standard;
(c) which is a biological agent;
(d) which is dust of any kind, except dust which is a substance within paragraph (a) or (b) above, when present at a concentration in air equal to or greater than—
(i) 10 mg/m3, as a time-weighted average over an 8-hour period, of inhalable dust, or
(ii) 4 mg/m3, as a time-weighted average over an 8-hour period, of respirable dust;
(e) which, not being a substance falling within sub-paragraphs (a) to (d), because of its chemical or toxicological properties and the way it is used or is present at the workplace creates a risk to health;
CLP
EC Regulation No 1272/2008 Classification, Labelling and Packaging or Substances and Mixtures (CLP)
An employee’s exposure to lead is significant if one of the following three conditions is satisfied:
1) Exposure exceeds half the occupational exposure limit for lead.
2) There is a substantial risk of the employee ingesting lead.
3) If there is a risk of an employee’s skin coming into contact with lead alkyls or any other substance containing lead in a form, for example: lead naphthenate, which can also be absorbed through the skin.
Lead can also be easily absorbed through ingestion. To avoid this risk, it is important to
make sure that employees do not eat, drink or smoke in any place which is liable to be contaminated by lead.
If there is significant exposure to lead, the monitoring of employees’ exposure should be carried out by both:
Air sampling.
Measuring the concentration of lead in their blood or their urine (for work with lead alkyls).
These two approaches have complementary roles.
Action levels are concentrations of lead in blood set below the appropriate suspension limit. If these are reached or exceeded, the employer must:
Carry out an urgent investigation to find out why.
Review control measures.
Take steps to reduce the employee’s blood-lead concentration below the action level, so far as is reasonably practicable.
Asbestos is classified as
a category 1 carcinogen
exposure to asbestos at work
Directive 2009/148/EC - exposure to asbestos at work
The duty holder has to take reasonable steps to find out if there are asbestos containing materials (ACM) on the premises and, if so, how much, where they are and what condition they are in. This can, but does not have to, involve a survey. A survey can be:
Management survey: This is to locate all materials that are likely to contain asbestos. It will usually involve the taking of samples to confirm the presence of asbestos. If no samples have been taken then it is assumed that all materials contain asbestos.
Refurbishment/demolition survey: These involve getting full access to all parts of the building using destructive inspection if necessary and will involve the taking of samples which are analysed to confirm whether asbestos is present. This type of is usually used before major refurbishment or just before demolition.
No employer can carry out demolition, maintenance or any other work which exposes, or may expose, their employees to asbestos in any premises unless they have:
carried out a suitable and sufficient assessment as to whether it is asbestos, what type
of asbestos, contained in what material and in what condition is present or is liable to be
present in those premises; or
(b) if there is doubt as to whether asbestos is present in those premises he—
(i) assumes that asbestos is present, and that it is not chrysotile (white asbestos) alone
An employer must hold a licence before undertaking any licensable work with asbestos. ‘Licenseable work with asbestos’ is defined as work:
where worker exposure to asbestos is not sporadic and of low intensity; or
where the risk assessment cannot clearly demonstrate that the control limit will not be exceeded ie 0.1 asbestos fibres per cubic centimetre of air (0.1 f/cm3) (averaged over a four hour period); or
on asbestos coating; or
on asbestos insulation or asbestos insulating board where the risk assessment demonstrates that the work is not short duration work, eg when work with these materials will take no more than two hours in any seven day period, and no one person works for more than one hour in that two hour period.
