Posted By Jay Joshi Mark, GHS has been implemented in EU by a direct acting regulation, known as CLP (which is not a directive) therefore GB does not have to make GB regulations CHIP 4 enables continiuty of CHIP through the transition period AND permits enforcement of CLP Please refer to:- http://www.hse.gov.uk/chip/issues.htm http://www.hse.gov.uk/chip/law.htm http://www.hse.gov.uk/ghs/eureg.htm There is a transition period. The CHIP 4 Regulations allow chemical suppliers to apply the requirements of the CLP Regulation (as an alternative to those in CHIP) in line with the transitional arrangements of the CLP Regulation. These arrangements comprise a two-stage process whereby substances have to be reclassified and relabelled by 1 December 2010, and mixtures (previously called preparations), by 1 June 2015. Substances and mixtures already on the shelves on these dates, can continue to be supplied until 1 December 2012 and 1 June 2017 respectively.

Posted By mark linton Thanks for the response COSHH Assessor - It does say it is toxic by inhalation but it's LC50 is 25mg/l - which also puts it outside the toxic range for vapours / gases etc as defined it the comparison table. The figure on the data sheet is over 2 hours where as the information in the comparison table is 4 hours - does that make a big difference? Thanks

Posted By Jay Joshi Mark, The comparisons you are referring to were with the existing (old) EU system that is being replaced by the new CLP Regulation Under the existing (old) system, level of toxicity from 2000mg/kg to 5000mg/kg doesn't warrant classification/labelling For acute toxicity, classification & labelling of substances under the new CLP regulation can be allocated to one of four toxicity categories based on acute toxicity by the oral, dermal or inhalation route.(GHS has 5 categories!)refer to Annexe I The new CLP regulation also means that the COMAH regulations will need to be updated to include the new CLP classifications (as well as the existing CHIP classifications until the transition period). The EU is apparently working on changing the Seveso II/ COMAH boundaries, with the intention that businesses are not brought into COMAH because of CLP. The Hazard and Precautionary statements that will replace the risk and safety phrases are in Annexes 3 and 4 of CLP The text of the regulation and all the seven annexes (1300 pages!!!) can be downloaded at:- (REGULATION (EC) No 1272/2008 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 16 December 2008 on classification, labelling and packaging of substances and mixtures, amending and repealing Directives 67/548/EEC and 1999/45/EC, and amending Regulation (EC) No 1907/2006) http://eur-lex.europa.eu...008:353:0001:1355:EN:PDF For information purposes, there is an English version of the Regulation available as Word files. Please note that these individual files of the enacting regulation and annexes of 16 December 2008, have some small editorial differences with the final version published in the Official Journal. (Only the version published in the Official Journal of the European Union has legal value). http://ec.europa.eu/ente...legislation/index_en.htm The annexes have details on:- Annex I Classification And Labelling Requirements For Hazardous Substances And Mixtures Annex II Special Rules For Labelling And Packaging Of Certain Substances And Mixtures Annex III List Of Hazard Statements, Supplemental Hazard Information And Supplemental Label Elements Annex IV List Of Precautionary Statements Annex V Hazard Pictograms Annex VI Harmonised Classification And Labelling For Certain Hazardous Substances Annex VII Translation Table From Classification Under Directive 67/548/Eec To Classification Under This Regulation For example, in context of Acute Toxicity, substances can be allocated to one of four toxicity categories based on acute toxicity by the oral, dermal or inhalation route according to the numeric criteria shown in Table 3.1.1. Acute toxicity values are expressed as (approximate) LD50 (oral, dermal) or LC50 (inhalation) values or as acute toxicity estimates (ATE). Explanatory notes are shown following Table 3.1.1. ‘Translation’ table Annex VII of the new Regulation presents a ‘translation’ table which can be used to ‘convert’ classifications made under the current Dangerous Substances Directive to the new classifications made by applying the GHS criteria. Where there is no direct one-to-one equivalent, the Annex has assigned the least severe classification and places a duty on the supplier to decide if a more severe classification is needed. This annex is intended to be used by those substances and mixtures that have already been self-classified under the existing European legislation, and where the hazard categories identified are equivalent. The European Commission intends the table to help suppliers/importers of substances and mixtures fulfil their obligations under the new Regulation without having to reclassify, as long as the chemical has already been classified under the existing system. If a supplier/importer chooses not to use the table they must fully re-evaluate the substance or mixture using the criteria in the Regulation. RIP 3.6: Guidance on classification and labelling under global harmonised system The European Commission has designed the proposed GHS-based Regulation to fit in with other European chemical legislation. The most relevant piece of legislation is the Regulation on the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) that came into force in June 2007. Complying with the GHS-based Regulation will be necessary to achieve compliance with REACH. The European Chemicals Bureau is responsible for developing methodologies, tools and technical guidance needed for REACH through a number of REACH Implementation Projects (RIPs). As part of this RIPs work, RIP 3.6 aims to produce guidance on the classification and labelling under the proposed GHS-based Regulation. The work on this RIP is underway . As of now, RIP 3.6 is has not been published. There is a good introduction to CLP at http://www.ttenvironment...p-details-april-2009.htm