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Guru  
#1 Posted : 11 November 2009 10:41:34(UTC)
Rank: Super forum user
Guru

We are a cosmetics company that receive volumes of perfumes / oils from suppliers. Unfortunately some products that are flammable are not labelled as such, and are delivered in 200KG drums, causing us problems as we have our flammables stored at a specified location. I'm of the understanding that the CHIP regulations do not apply as the product is classified as a cosmetic, and as such the Cosmetic Products (Safety) Regulations 2004 (as amended) are applicable, however I cannot see any requirement to labelling product flamm / highly flamm etc. I would like to get my facts right before making contact to the supplier with regard to labelling, or lack of it for that matter and would appreciate any guidance anyone could offer. Thank you in advance.
mtaylor  
#2 Posted : 11 November 2009 22:52:14(UTC)
Rank: Forum user
mtaylor

Gordon - sorry but I can't help with your specifc query but I have a similar concern with 10kg tins of worktop oils with no indication on the tin that they are flammable My understanding is that CHIP should apply to ALL hazardous materials but lets hear what others think Martin
teh_boy  
#3 Posted : 12 November 2009 08:09:06(UTC)
Rank: Super forum user
teh_boy

CHIP does apply for supply http://www.hse.gov.uk/chip/index.htm However is the substance flammable in the strictess sense of the word. It's all down to flash point! Do they provide a MSDS as was required under CHIP (Now REACH) -this will (well should) contain flash point data so you can decide how flammable it is.
Guru  
#4 Posted : 12 November 2009 08:43:59(UTC)
Rank: Super forum user
Guru

Thanks for all your input so far :) With regard to CHIP, there are some chemicals that are is not covered, specifically medicines and cosmetics, and the reason is due to more specific laws covering them. Our situations is having a product being delivered in volume, unlabelled and the MSDS sheet saying nothing about being flammable. We know its flammable because we have done our own flashpoint testing, which came in at 25oC. My concern is two fold, firstly volumes of flammable product being transported unlabelled and secondly introducing a new procedure in dealing with flammables upon arrival. Simply put, I want to know what legislation can I point to with regard to labelling flammable perfumes to a supplier? I dont want to stick my neck out by saying you must bla bla bla, where there is no legislation to back me up. Any advice much appreciated.
teh_boy  
#5 Posted : 12 November 2009 10:37:33(UTC)
Rank: Super forum user
teh_boy

CHIP http://www.opsi.gov.uk/si/si2002/20021689.htm "(3) These Regulations shall not apply to a substance or preparation which is (d) a cosmetic product within the meaning of the Cosmetic Products (Safety) Regulations 1996" http://www.opsi.gov.uk/s...6/Uksi_19962925_en_1.htm Reg 8 - I would still say CHIP applies in this case (and REACH) as the above regs appear more concerned with end user safety... I am no expert on cosmetics mind :)
dangerous dave  
#6 Posted : 12 November 2009 17:10:06(UTC)
Rank: New forum user
dangerous dave

Gordon, I do not know about CHiP rules but for certain the transport of dangerous goods regulations will apply (if flash point is below 60C). Transport rules do not exempt cosmetics. They would have to be labelled for transport i.e. Class 3 diamond and UN number for transport
Guru  
#7 Posted : 13 November 2009 10:27:53(UTC)
Rank: Super forum user
Guru

Arent those regulations more applicable to labelling / identifying on the actual transporter (lorry) rather than the individual drums? Pardon my ignorance.
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