Implementation of CLP & GHS for PPPs - are we ready?

Phil Todd: ECPA Classification and Labelling Expert Group

ECPA/ECCA Crop Protection European Regulatory Conference March 2015

One off:

– Transitioning labels to the new rules

On going

– Continuing evolution of GHS/CLP

– New/updated classifications of substances from suppliers and RAC

– New EU specific issues e.g. Poison Centers

Are we ready now and in thefuture?

We must already have:– Implemented CLP labels for all substances (intermediates, active

ingredients, many raw materials and co-formulants)

– Relabeled any existing stocks of these substances

– Updated corresponding Safety Data sheets and sent them to anyone who handles these substances

By 1st June 2015 (at the latest)– Implement CLP labels for all newly produced products (mixtures)

– Update corresponding Safety Data Sheets updated and send them to customers

– Plan to consume or relabel existing stocks by 1st June 2017

Transition to CLP: What we have to achieve

Are we ready now?

Mixture reclassification status

Registration authorities approachEnlightened

An industry responsibility: “Get on with it”E.g. UK CRDConsistent with ECPA view

PragmaticInitially required notification and approval before relabellingAvailable resource not adequateChanged to selective review “after the event”e.g. Belgium

UnrealisticNotification and approval required before relabellingInadequate resources and processesComplicated by incorrect understanding of requirementsConflict between EU and national law

Action for companies

Registration authorities approachEnlightened

Make sure that we deliver

PragmaticMake sure that we deliverChallenge any incorrect reviews

UnrealisticHighlight the impossible position that companies will be in

If nothing changes, ensure that we comply with CLP (in an open and transparent way)

Constant engagement with Commission

– 1 data set + 1 rule ≠ 1 classification

– Highlighting process issues

Commission does not recognize the problem

We need concrete examples of

– Classifications from authorities that do not follow CLP

– National processes that prevent compliance with CLP

What ECPA is doingHow you can help

Watch-outs for industry

• Do not expect classifications and labels to be consistent between products and countries

• “Similar” products can legitimately vary• Registration authority “peculiarities” act against harmonization

Consistency

• Physically changing labels is not a “5 minute job”• Defining the classification on paper is not the end of the processTiming

• CLP and transport classifications should be consistent• Manufacturing and Storage facilities affected via Seveso directive

Downstream impacts

• In a typical supply chain, there are multiple “placing on the market”• CLP obligations start with the first “placing on the market” and not the last

“Placing on the market”

• We can expect systematic enforcement, often triggered by REACH projects• Enforcement often led by non-agricultural ministries• Enforcement often “tick box” approach

Enforcement

Are we ready for the future?

CLP continues to evolve

New/amended hazard criteriaWe’ve already had

Skin sensitization subcategoriesOzone depleting substancesChronic aquatic toxicity

On the wayUnstable explosivesPyrophoric gasesCombustible dusts?………

We need to review our classifications every time that criteria are added or changed

CLP continues to evolve

Updates to P and H statementsWe’ve already had

Numerous changes to P statements• P281, P285 deleted• Numerous changes to wording• “Remove victim” “Remove person”

(P304 + P340)• ……….

On the wayFortunately none in GHS Rev.6Expect more in GHS Rev.7Standing working group at UN

Even if classifications don’t change, need to constantly review labels

There is now a structure that

encourages constant change

Substance classifications change

• A classification factory• 50 classifications per year

• 1 ATP per year• Every classification change has to be

implemented for substance and relevant mixtures

RAC

• Deadlines + continuous process• New data miraculously being found• Reevaluation of old data• Limited generation of new data

• Substance self classifications changing• Every classification has to be implemented for

substance and relevant mixtures

REACH

Harmonised (at the upper level) information submission requirements

Less likely to harmonize submission methods

Unique Formulation Identifier (UFI) on every label

EU specifics: Poison Centers

Closing thought

Classification and Labelling has moved from a project approach to a continuous process approach. Have we

also changed our approach?

Thank You