Did the extent of chemical use change?

The CLP Regulation has been in the implementation phase for a long time and has also started to become familiar to end-users in the form of new labels, classifications and safety data sheets (SDS). In addition, local legislation and regulations have been steadily moving towards the requirements of the CLP Regulation. The Government Decree on the Control of the Handling and Storage of Dangerous Chemicals (685/2015), which entered into force in June, is the latest step towards this.

It is not easy to answer yes to this question. A quick glance at the Regulation (685/2015), for example, reveals that at least the calculation of the scope of use based on the new classifications in Annex 1 of the Regulation is far from straightforward.

The tables in the Annex refer to chemical categories and named chemicals. Of course, there is nothing unclear about the concepts in the table, let alone the numerical values, and a little familiarity will give you a good idea. But, when you get closer to the practical implementation in companies to calculate the extent of use, problems start to arise. The reason for these problems is that, although the classification and legislation are up to date, the KTTs for chemicals available to companies are not yet fully in line with the above. This results in a discrepancy in the calculation of the extent of use - new classifications in the tables and new and old ones in the SBS, alone or in combination.

The calculation runs smoothly with the availability of the revised safety data sheets with H-phrases and categories. Unfortunately, the situation is still such that a CLP-formatted SSC is not yet available for all chemicals - especially mixtures - and the calculation should take these chemicals into account.

How then is the scope calculated in these situations? Use the conversion table in the CLP Regulation and the calculation starts to go much more smoothly. As a result of our long work, we have also developed tools to make this calculation easier, and the feature will be moved into the PRO24 Chemicals module in the future to be continuously implemented.

So the groundwork is in place for us and we are ready for the challenges, but what is the situation in your company? Contact us - we're ready to help.