REACH & GHS
>> TFL Information on REACH
TFL is informing tanners in the EU that TFL has pre-registered all currently supplied chemical substances that eligible for REACH pre-registration. If any decisions are made in the coming years to discontinue with certain substances then the customer will be informed in plenty of time. At this stage the EU tannery customers need only to check with their supplier that their supply of chemicals is going to continue. If a non EU customer is only selling leather to the EU, the customer needs to do nothing as long as their leather does not contain substances which are forbidden or restricted in the EU. It should be noted that some EU leather specifiers and buyers may insist that only REACH registered substances are used to make the leather. This is not law but it is a possible consequence of the REACH regulation. If a customer outside of EU is exporting chemical substances to the EU, they should be well aware of the REACH regulation and they must have an agent in EU (legal representative) who preregisters the substances on their behalf. TFL also confirms that all European TFL Safety Data Sheets, that have been created after June 1st 2007 comply with the Regulation (EU) No 1907/2006 (REACH).
>>TFL is introducing GHS
In the end of 2008 the EU has introduced the Globally Harmonised System for Classification and Labelling of Chemicals (GHS). For mixtures, these new rules will be obligatory as of June 1st 2015 but may already be applied now. TFL Ledertechnik GmbH and TFL Italia S.p.A are among the first suppliers of chemical mixtures in the EU to introduce GHS.
How will the transition to GHS proceed?
- TFL plants in France and Italy will start with the implementation of GHS in May and June 2011, other TFL manufacturing plants will follow within approximately one year
- GHS will be applied product by product in the normal course of the manufacturing cycle
- Products on stock with the previous label will not be re-labelled
During the transition period the sending of updated safety data sheets might occasionally be delayed or some packages of a certain product might come with GHS labels and others with the previous labels. All involved teams are working hard to manage the introduction of GHS as smoothly as possible, nevertheless temporary inconsistencies cannot absolutely be excluded.
- In the beginning of June 2011 wetend products will be delivered to our customers with GHS labels
- In parallel to products labelled according to GHS updated safety data sheet containing the new GHS information will be sent to our customers
The new EU GHS regulation
GHS has been developed by the UN in an effort to unify the many different systems for hazard classification and communication worldwide. It has been implemented in the EU with regulation 1272/2008. For substances, the new GHS rules have been obligatory as of December 1st 2010, for mixtures they must be applied from June 1st 2015. In addition to the EU, several countries worldwide are currently introducing the GHS system
The previous EU system with its 15 classes of hazardous properties will be replaced by the GHS system with 28 hazard classes. Most of the additional hazard classes are in the area of physical hazard. For example we will now have new hazard classes for gases under pressure and for substances that are corrosive to metals. These hazardous properties are not considered in the current EU system. In each hazard class there may be several hazard categories depending on the severity of the hazard. For example the hazard class of acute oral toxicity is subdivided into categories 1 to 4. The higher the number of the toxicity category, the lower the toxic effect of the chemical.
The main elements of hazard communication are the product label and the safety data sheet. With GHS the well-known orange hazard symbols, R-phrases and S-phrases are replaced by red-bordered hazard pictograms, H- and P- statements (Hazard statements, Precautionary statements). In addition a new signal word appears on the hazard label in certain cases.
With GHS more products will have a hazard label. Also, the number of hazard pictograms may be higher than the number of hazard symbols in the previous labelling system. This does not mean that the product itself has changed. However, the rules for classification have changed and have become stricter.