Same intrinsic hazards but different regulatory goal posts!
After over forty years of classifying and labelling according to the Dangerous Substances Directive, 67/548/EEC (DSD) and more recently the Dangerous Preparations Directive, 1999/45/EC (DPD) the Regulation (EC) No 1272/2008 on classification, labelling and packaging substances and mixtures (CLP Regulation) came into force in 2009.
This Regulation is the implementation of the GHS (Global Harmonised System) with the overarching aim of harmonising hazard communication; which for those who import/export chemicals from around the world know can only be a good thing.
There are a lot of similarities and of course differences between the CLP Regulation and the Dangerous Substances Directive (DSD)and Dangerous Preparations Directive (DPD); but the goal of protecting both man and the environment by means of appropriate labelling still remains the same.
As we know, the outcome of classification and labelling of substances and mixtures forms an integral part of hazard communication of SDS and, without adequatetoxicological/ecotoxicological/ physicochemical data (if self-classifying) the whole process can be highly problematic.
Do I need to test for all endpoints?
Similar to the DSD/DPD there is no legal obligation to undertake testing for human health and ecotoxicological endpoint classification under CLP, but the onus is on the supplier to have done all they could to assess any potential hazardous effects; this could be by means of read across from structurally analogous products, etc.
How I can help
If you need help with classification and labelling of your products please do contact me. I have extensive experience of classifying and labelling substances/mixtures in accordance with different criteria (which includes CLP/GHS).
Furthermore, I offer both webinar and face to face styled training courses in classification and labelling in accordance with CLP/GHS; which many companies have found to be very useful! Contact me for more details.
Tel: +44 (0)7985 923707