Transporting chemicals can be extremely dangerous for all involved throughout the supply chain. However, according to a recent report from the Chemical Business Association (CBA) accidents remain at an all time low1. James Killerby, director of Hibiscus, leading supplier of labels and software for the chemical and transport industries, explains how compliant labelling is playing an increasingly important role in keeping the number of accidents down.
Modern industry relies heavily on a number of potentially dangerous chemical substances. If mishandled, these hazardous chemicals can be extremely harmful to those who come into contact with them, especially during handling and transportation. Chemical products are often corrosive, combustible, temperature-sensitive, poisonous or otherwise dangerous to employees and the environment and can lead to an increased danger throughout the supply chain.
Whilst steps are in place to reduce chemical-related workplace injuries, occasionally major accidents can occur. This not only poses a serious health risk to supply chain workers and members of the public, but could also have vast financial implications for the companies involved.
The legislation surrounding the transportation and handling of potentially hazardous chemicals is becoming progressively more complex, as chemical products are shipped to a wider global market. For those involved in the chemical supply chain this poses a particular challenge, ensuring chemicals are shipped quickly and efficiently, whilst also ensuring staff remain safe.
Putting a label on chemical safety
Due to its inherent risks to human health, the handling of hazardous chemicals is subject to regulatory control at every stage of its development, and this compliance requirement is especially evident in the supply chain. Key to this regulatory adherence is labelling, with complex legislation surrounding the movement of chemicals particularly important to the industry.
The risks associated with incorrect, missing or insufficient labelling of packaging, as well as the chemical containers themselves, are abundant. If chemicals are wrongly labelled, or labels become damaged during transit, making them difficult to read, this can have highly dangerous consequences.
As the breadth and reach of international trade has grown, there has been an increased demand for a system of labelling that is understandable to all, regardless of nationality or first language. The United Nations has therefore created the Globally Harmonised System of Classification (UN GHS).
CLP is the European Union’s legislation to underpin the new system, and it uses the UN GHS as its base for the Classification, Labelling and Packaging – hence the name – of substances across all EU countries. The aim of the GHS is to apply the same criteria for categorising chemicals worldwide, according to their health, environmental and physical hazards, and the subsequent requirements for labelling and safety data sheets.
The size of labels, types of supplemental information and precise position of data on the label, are all covered under the CLP rulings. Companies now have to follow strict adherence to these guidelines to ensure they are fully compliant within the remit of the new CLP system.
There are new “hazard” labels and guidelines around the use of words, phrases and terms. The dangerous goods list also has several changes and there are alterations to packing instructions with some specific to the method of transportation. On the road specifically, legislation on the construction of vehicles has been amended and there are new EN and ISO standards.
The new legislation aims for simplicity and accuracy in labelling but the definitions themselves are complex so seeking advice from industry experts is advisable. When commissioning labels, consideration should be given to the heat and humidity they will be expected to withstand and what their life cycle will involve – a factor particularly relevant in the chemicals sector, where products often require temperature controlled transportation. Sometimes labels with adhesives, which are produced to a higher specification, are required.
In order to ensure simplicity and global understanding of chemical labelling, new hazard symbols have been introduced. Nine red diamond-edged hazard pictograms have been launched to gradually replace the familiar old orange and black square CHIP danger symbols. This includes three new symbols:
Most industrial chemicals are covered by the CLP regulation, though some that have a more specialised job are covered by more specific legislation. It doesn’t, for example, apply to radioactive substances and mixtures, or to mixtures for scientific research and development which aren’t placed on the market and are only used in controlled conditions. Specific groups of chemicals, which may be subject to additional control, i.e. pesticides, biocides and carcinogens, are also exempt.
The more specific chemical groups do however fall within the scope of REACH, the European Union Regulation, which covers the Registration, Evaluation, Authorisation and restriction of Chemicals. REACH applies to substances manufactured or imported into the EU in quantities of 1 tonne or more per year. It concerns individual chemical substances, but does not include human and veterinary medicines, food and food additives or plant protection products, polymers and biocides, which are all covered by more specific legislation such as the Biocidal Products Regulations (BPR).
Since REACH covers the entire supply chain, compliance requires a collaborative effort by all involved in the chemicals transportation. Meeting the requirements of REACH can vary significantly depending on your role in the industry, as well as the product you manufacture.
With an emphasis on a “no data, no market” approach, the REACH Regulations place a responsibility on industry to provide safety information on chemicals, such as how the substance can be safely used and the risk management measures that need to be put in place to avoid harm to employees. As a result, supply chain management is one of the main values of REACH, with manufacturers and importers required to gather information on the properties of their chemicals and register this information in a central database with the European Chemicals Agency (ECHA).
This regulation has been the catalyst for improvements in the safety of workers throughout the supply chain, with many of the most dangerous chemicals – referred to as Substances of Very High Concern (SVHC) – identified and substituted with less hazardous ones.
Carriage of chemicals by road
Although companies need to be aware of the changes to chemical labelling and packaging under CLP regulations and requirements of legislation such as REACH, they must also take into account the demands placed upon them when transporting hazardous chemicals by road.
The high potential for incidents such as traffic accidents, spillages, fires, explosions or chemicals burns during the carriage of dangerous chemicals by road, means the legislation surrounding the process is equally complex.
When transporting hazardous goods by road in the UK and the EU, packages and vehicles must be properly labelled to conform to the strict CDG (Carriage of Dangerous Goods) and ADR Regulations. Hazard warning labels, diamonds, placards, Hazchem panels and panel holders must be attached to vehicles to ensure full compliance.
Equally importance to the safe transportation and handling of hazardous materials is export documentation, and more specifically dangerous good notes. A dangerous goods note is a transport document that provides details about the contents of a consignment to carriers, receiving authorities and forwarders. Much like the labels themselves, such a document details what the dangers of the goods are, further reducing the risk of accidents and ultimately employee injuries.
ADR not only serves the purpose of protecting everyone directly involved, such as the consigner or carrier, but also those who may become involved if an accident or spillage occurs, such as members of the emergency services and the public. The regulations place responsibility on everyone involved in the transportation of hazardous materials, to ensure the risk of incidents is minimised and a fast and effective response can be achieved if they do occur.
Given the inherent risks associated with handling hazardous chemicals, and the strict regulatory compliance surrounding it, seeking industry expertise on legislative compliance is imperative, not only to avoid potentially costly fines but also to guarantee the safety of all staff throughout the supply chain.
As the supply chain continues to expand into new regions, crossing international borders, the number of people potentially at risk of chemical accidents grows. All in the chemical supply chain must take all necessary measures to prevent major accidents involving dangerous substances, and limit the consequences to people and the environment of any major accidents which do occur.
James Killerby is director of Hibiscus PLC, a leading supplier of labels and software for the chemical and transport industries.
Hibiscus, a family business based in Yorkshire for 35 years, is a one-stop shop for everything needed to produce high quality dangerous goods and chemical labels for storage and transportation. They are one of the UK’s leading manufacturers of ADR hazard warning diamonds and placards, with thousands of labels in stock, ready for next day delivery. The company also produces software for the classification and labelling of hazardous substances and the authoring and management of Safety Data Sheets. Hibiscus has expert, up-to-date knowledge of legal requirements and a committed team of 32 employees who guarantee a high level of service.