Compliant Labeling of Hazardous Chemicals

A label is the most appropriate tool for learning about a chemical's hazards and the measures to be taken against those hazards. For this reason, a label must present its message to the reader quickly, clearly, simply, and in an understandable manner and format. Proper chemical labeling has been one of the leading issues in the global chemical industry for decades. The fact that chemical labeling rules differ between countries creates problems in international trade. Additionally, incorrect or incomplete labeling performed by persons with insufficient knowledge and competence can result in inadequate information for users, leading to various workplace and usage accidents, occupational diseases, and harm to individuals due to insufficient precautions taken as a result of incomplete or incorrect information. At the same time, it can lead to incorrect packaging selection, unsuitable storage and transport methods, and incorrect method selection during production, thereby creating both accident potential and operating costs higher than planned. Due to the high level of importance that labeling carries, the relevant local and/or regional official authorities of countries have made the practice of labeling hazardous chemicals mandatory and harmonized at the global level through official regulations they have published. The Globally Harmonized System (GHS) was created by the United Nations for precisely this purpose. Image 1. Industrial Chemical Labeling GHS aims for any chemical to be evaluated by different countries under the same classification-labeling-packaging conditions, and thus for common labeling to be carried out. As a result of labeling performed under different conditions between countries, disruptions occur in the commercial journey of the chemical and even obstruct the flow of commerce. With GHS, using common elements in hazard communication, the aforementioned commercial problems have been resolved. The labeling process of a chemical is actually the second stage of the process that will be discussed shortly. Before the labeling process, the hazards of the chemical substance or mixture must be identified. To determine the hazards of substances:

• Tests (toxicological, ecotoxicological, irritation/corrosion, carcinogenicity, etc.) can be conducted,
• Data from other substances with similar structures on which various tests have been performed can be used,
• Literature studies can be used,
• QSAR databases can be used. To determine the hazards of mixtures:
• Tests (toxicological, ecotoxicological, irritation/corrosion, carcinogenicity, etc.) can be conducted,
• Data from other substances with similar structures on which various tests have been performed can be used,
• Literature studies can be used,
• Calculation Method: This is the most frequently used method.

The person applying this method must be familiar with Regulation No. 28848 on CLP and its annexes. For this very purpose, the person using the calculation method must be a certified individual who has successfully passed an examination organized by an accredited body. This person's title is Certified Safety Data Sheet (SDS) Preparer. The hazard classification of a chemical substance or mixture (H codes and statements) is determined through Regulation No. 28848 on CLP and its annexes (particularly Annex 1). Details regarding the calculation method are provided in this annex. The labeling rules are also contained in this regulation and its annexes.

Labeling Elements

Regulation No. 28848 on CLP specifies the mandatory elements that must appear on a label. The hazard statements (H codes) identified for a substance or mixture are used as the starting point for determining these elements. Although the mandatory label elements vary depending on the type of chemical product, the elements listed below (according to Article 19 of Regulation No. 28848 on CLP) are those that must be used for all product types with a few exceptions:

• Supplier's name, address and telephone number,
• The nominal quantity of the substance or mixture in the package presented to the public, unless the quantity is indicated elsewhere on the package,
• Identity of the substance or mixture,
• Hazard pictograms,
• Signal word,
• Hazard statements (use of H codes is not mandatory on the label),
• Precautionary statements (use of P codes is not mandatory on the label),
• For a substance or mixtures, the names of substances causing the hazards specified in Article 20 of Regulation No. 28848,
• If applicable, EUH statements.

Image 2. Sample Supply Label

Identity of the Substance and Mixture (Regulation No. 28848 on CLP, Article 20)

A substance label must contain the name of the substance and its EC or CAS number. A mixture label must contain the following elements:

• The trade name or designation of the mixture,
• The identities of all substances present in the mixture that contribute to the mixture being classified as having acute toxicity, skin corrosion or serious eye damage, germ cell mutagenicity, carcinogenicity, reproductive toxicity, respiratory or skin sensitization, specific target organ toxicity or aquatic hazard.

Hazard Pictograms (Regulation No. 28848 on CLP, Article 21)

Hazard pictograms are determined according to the H codes corresponding to the classification of products. All hazard pictograms and the conditions for which hazard pictogram is to be used are provided in Annex 5 of Regulation No. 28848 on CLP. Each pictogram has its own code. There are a total of nine hazard pictograms, and their codes are like GHS01, GHS02 examples. For example, the flame pictogram is GHS02. The skull pictogram is GHS06. Codes are not used in labeling; the pictogram itself is used directly. Image 3. CLP hazard pictograms Hazard pictograms must be a black symbol on a white background with a clear wide red border. The label background color must contrast with the hazard pictogram or must not diminish the prominence of the pictogram's border. Since the most basic purpose of a label is to present a product's hazards in a simple manner, when there are many hazard pictograms, a filtering process can be performed between the pictograms. This process must be carried out within the conditions specified in Article 28 of Regulation No. 28848 on CLP. If filtering is to be performed, the filtered pictogram is always for the hazard of lower severity. Another important detail is that the filtering process must always occur within each of the three hazard groups. That is, pictograms for physical hazards, health hazards, and environmental/aquatic hazards can be filtered within their respective groups. For example, a pictogram for physical hazard cannot have a precedence effect over a health or aquatic hazard pictogram.

Signal Word (Regulation No. 28848 on CLP, Article 22)

Signal words are determined according to the H codes. There are two signal words: Danger or Warning. Danger indicates a higher degree of hazard. When the signal word "Danger" is used on the label, the signal word "Warning" does not appear.

Hazard Statements (Regulation No. 28848 on CLP, Article 23)

The complete list of hazard statements is provided in Annex 3 of Regulation No. 28848 on CLP. The descriptions included in the hazard statements must comply with the provisions in Annex 3. In other words, you must use the statements specified in the annex. This is an important matter, as using different statements for the same H code is one of the fundamental principles for creating a harmonized and standardized label. Incorrect labeling seen in industry, where different statements are provided for the same H code, can result in misunderstanding of the hazard and insufficient precautions being taken. Bülent Özdemir / Chemical Legislation Senior Expert Manager / CRAD Environmental Risk Analysis Audit and Training Services Inc.