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antbruce001  
#1 Posted : 21 June 2010 15:24:47(UTC)
Rank: Forum user
antbruce001

Can anybody clarify the following statement on the HSE website relating to the transistional arrangements for the CPL Regs and CHIP4 "There are certain limited circumstances where these transitional arrangements for substances and preparations can be extended. The re-labelling and re-packaging of substances and mixtures which are already in the supply chain (‘on the shelves’) on the above compliance dates, may be postponed until 1 December 2012 and 1 June 2017 respectively" My interpretation of this is that it only applies to stock that is 'out of the gate' and already available for sale on the appropraite 'compliance date'. All new stock, even existing preparations must be classified under CLP by the manufactures after the 2015 deadline. It does not mean that if the preparation already exists that it can continue to be labelled under the 'old' system until the extended deadline. . I ask the question as I was recently running a training course and the client was insistent that they had until 2017 to impliment CLP on their products as they are classified as preperations. Tony.
Kay  
#2 Posted : 21 June 2010 15:31:28(UTC)
Rank: Forum user
Kay

Hi Tony I had a look at this recently and although I'm not in the chemical industry I completely agree with you, i.e. only if it has left the manufacturer's premises tdoes it qualify for the extension - but I can see where the ambiguity comes from. Maybe the HSE infoline could clarify? Kind regards Kay
jay  
#3 Posted : 21 June 2010 15:57:36(UTC)
Rank: Super forum user
jay

For authoritative information, please contact:- REACH and CLP UK Competent Authority Helpdesk, Health and Safety Executive 2.3 Redgrave Court, Merton Road L20 7HS Bootle Merseyside E-mail: UKREACHCA@hse.gsi.gov.uk There is useful guidance :- The Introductory Guidance on the CLP Regulation: http://guidance.echa.eur.../clp_introductory_en.pdf (page 23 has the timelines) http://echa.europa.eu/clp/clp_help_en.asp
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