- Why have the changes occured?
The changes are due to the introduction of the new Classification Labelling and Packaging (CLP) regulations.
- What are the CLP regulations?
European Regulation (EC) No 1272/2008 on classification, labelling and packaging of substances and mixtures came into force on 20 January 2009 in all EU Member States. It is known by its abbreviated form ‘the CLP regulations’, or just plain ‘CLP’.
- How are the CLP Regulations linked to GHS?
The CLP Regulations adopt the United Nations’ Globally Harmonised System (GHS) on the classification and labelling of chemicals across all European Union countries.
As GHS is a voluntary agreement rather than a law, it has to be adopted through a suitable national or regional legal mechanism to ensure it becomes legally binding. This is what the CLP regulations do.
- When did the CLP regulations come into force?
The CLP Regulations entered into force across all EU member states on 20 January 2009.
However, CLP was introduced gradually and had a fairly lengthy transitional period before it applied in full on 1 June 2015.
The CLP Regulations associated with pure substances came into effect on 1 December 2010.
The CLP Regulations associated with mixtures and preparations came into effect on 1 June 2015.
- What types of chemical products does Magnaflux manufacture?
Magnaflux EMEAR principally manufactures mixtures and preparations, all of which were switched to CLP-compliant SDSs and product labels on 1 June 2015.
We also supply a small number of pure substances – for example, our activated carbon, used for filtration purposes. These products also have new CLP SDSs and labels.
- What actions did Magnaflux take for the 1 June 2015 deadline?
A number of actions took place on 1 June 2015, namely:
- All CLP format SDSs were made available for download via the Magnaflux website.
- All product manufactured from 1 June 2015 was labelled with CLP-format product labels.
- Language versions of our SDSs were made available for download via the Magnaflux website.
You should also be able to access Magnaflux EMEAR Safety Data Sheets by contacting your local distributor.
- Am I still allowed to use product that has the old product labels?
Yes. There are no issues associated with end users using product that has the old product labels.
However, if you wish to reassess the product based on the CLP changes please feel free to download the latest version of the SDS from our website and use this to build a chemical risk assessment.
- Will I still be able to access the old format of SDSs for product that I am still using?
The old format of SDSs were produced in what was known as REACH CHIP 4 format (according to Directive 67/548/EEC as amended & Directive 1999/45/EC).
If you require a copy of the original SDS produced under the REACH CHIP 4 regulations, contact us by email.
- What will I now see on my product labels?
By law, product labels now contain the following:
- New pictogram(s)
- Signal word (Danger/Warning)
- Product identifier
- Contacts details of the supplier – one primary address for aerosol products; our three European addresses for bulk products.
- Amount/quantity – expressed in millilitres/litres for liquid products and kilograms for solid products.
- Hazard statement(s). On our product labels, we have referenced the H statement numbers so that the user can cross-reference them.
- Precautionary statement(s). On our product labels, we have referenced the P statement numbers so that the user can cross-reference them.
- Additional information/supplementary information.
- What if my product label does not show the same information as Section 2.2 on the Safety Data Sheet?
Magnaflux Safety Data Sheets (SDSs) and product labels for product that is currently in production are required by law to carry the same information. The information for a product label comes from Section 2.2 (Label Elements) of the SDS. Magnaflux Safety Data Sheets are only updated when:
- There are regulatory changes that we are required to implement – for example the change from REACH CHIP 4 to GHS/CLP in June 2015.
- There are changes to information within the SDSs that have been provided to us by our raw material suppliers – for example REACH registration number updates.
- There are changes that come about as a result of a change to a raw material – for example, a raw material discontinuation.
Each SDS carries a version number and revision date. Our system identifies the version of the SDS by the year and the issue number in that year – for example 14.2 would be the second version released in 2014. The revision date and a description of the changes are also described within the SDS. The revision date is included at the top and bottom of the SDS and the description of changes is included at the bottom of the document.
Each product label carries a unique batch number.
- For bulk products, the batch number consists of seven digits. For aerosol products, the batch number consists of six digits. In both cases, the first two digits represent the year of manufacture (for example, 15 = 2015) and the third and fourth digits give the month of manufacture (for example, 07 = July).
- Some products that we supply are manufactured by Magnaflux in the US (14A, MG 410, 1 Grey, 8A Red). The US batch numbering system is different and consists of five numbers and a letter – for example, 12K112. The first two digits represent the year of manufacture and the letter represents the month of manufacture (A = January, B = February, C = March, D = April, E = May, F = June, G = July, H = August, J = September, K = October, L = November, M = December). So the batch number 12K112 indicates that the product was manufactured in October 2012.
Using this batch number you will be able to identify the age of your product relative to that of the SDS. For example, you may have a product with batch number 1401010 and an SDS for this product with version number 15.1 and revision date 18.05.15. With this scenario:
- The batch number 1401010 tells us that it was manufactured in January 2014.
- The SDS was issued on 18th May 2015.
- This tells us that the information on the product label will be different to that on the SDS.
Should you require an earlier version of the SDS, contact Magnaflux EMEAR at firstname.lastname@example.org.
- Some Magnaflux products now carry the GHS05 corrosive symbol; is this because the formulation for these products has changed, and does this mean that it should be treated as a corrosive liquid for transportation purposes?
The formulation for these products has not changed. However, under CLP, the boundaries for classification for eye irritation are much lower: where a product carries the hazard statement ‘H318 Causes serious eye damage’, there is a requirement to carry the GHS05 corrosive symbol for use of the product. However, from a transportation point of view the product is not classified as dangerous, and hence there is no requirement to carry the corrosive transportation symbol or for the product to be covered by a Dangerous Goods Note (DGN).
- How do the new pictograms compare with the old hazard symbols?
The new symbols comprise nine pictograms that consist of red diamonds that contain a black symbol. Many look similar to the old symbols although they cover a different range of hazards. There are three completely new symbols. The symbol ‘X’ (harmful/irritant) is no longer used.
- What GHS symbols/pictograms will I find on Magnaflux EMEAR products?
Magnaflux EMEAR products use five of the new GHS symbols/pictograms. More information on these can be found below:
||Example hazard class
|Aerosol, cat. 1.
Extremely flammable aerosol.
Pressurised container: May burst if heated.
May cause drowsiness or dizziness.
|May be fatal if swallowed and enters airways.
Causes skin irritation
Causes serious eye damage
|Hazardous to the aquatic environment.
||Toxic to aquatic life with long lasting effects.
- What are signal words?
The signal word alerts the user to the severity of the hazard:
- Danger indicates more severe hazards
- Warning indicates less severe hazards
- No signal word indicates low hazard although there may still be hazard statements
- What are hazard statements?
Hazard statements (H statements) replace the old risk phrases (R phrases) and describe the nature, severity and category of a product. Hazard statements are assigned to a hazard class and hazard category:
- Hazard class – describes the nature of the physical (fire, corrosion)/health/environmental hazard.
- Hazard category – criteria within each hazard class that specifies the hazard severity.
For example H412: Harmful to aquatic life with long lasting effects. This describes the nature of the hazard and also the degree of the hazard.
In addition the EU has introduced some supplementary statements, prefixed EUH, for example: EUH066: Repeated exposure may cause skin dryness or cracking. On our product labels these are identified in green.
- What are precautionary statements?
Precautionary statements (P statements) replace the old safety phrases (S phrases) and describe the recommended measures to minimise or prevent exposure to the product during use and disposal.
For example, P280: Wear protective gloves/protective clothing/eye protection/face protection.
P statements provide important information for conducting risk assessments and putting risk management measures in place.
- Where there is a change in classification, is this because Magnaflux EMEAR has changed its product formulations?
No. The changes that you are seeing to our SDSs and product labels have been brought about simply because the products are being classified under CLP and because CLP has different rules and ‘cut off limits’ around the classification of substances and mixtures.
By means of an example, products that were formerly classified as irritants may be seen to carry the new corrosive symbol, as these products are now seen as corrosive to the eye.
- We often use SDS information to derive our own chemical safety information. But when we do this we find we disagree with your classification. Why is this?
On an SDS information in section 3 is only given for the hazardous substances within a particular product. Coupled with this it is quoted in the form of a percentage range. Typically our products will contain chemical substances that do not need to be quoted in Section 3.
The overall classification of a product mixture (given in Section 2.1 of the SDS) will normally be based on the actual total concentration of all the ingredients. As such it may not reflect the total of all standard ranges quoted per substance in the SDS. Typically the classification will therefore be lower than the total of the maxima of each of the contributing ranges.
- Do I need to check the product classification information?
No. We are confident that our classifications are accurate and there should be no need to check the classification unless there are, for example, specific local country rules that ask for specific requirements.
The only way to check the classification provided in Section 2 is to have access to the full product formulation. Product formulation details are strictly confidential information that cannot be shared externally without a legal agreement being in place.
- How do I know that I have the latest version of a Safety Data Sheet?
All SDSs on the Magnaflux EMEAR website are the latest versions.
Magnaflux EMEAR operates under a system of version control for its SDSs to ensure that it is clear to our downstream stakeholders that which version of an SDS they are referring to. Our system identifies the version of the SDS by the year and the issue number in that year – for example 17.1 would be the second version released in 2017. The revision date and a description of the changes are also described within the SDS. The revision date is included at the top and bottom of the SDS and the description of changes is included at the bottom of the document.
- What policy does Magnaflux have for updating Safety Data Sheets?
Magnaflux SDSs are only updated when:
- There are regulatory changes that we are required to implement.
- There are changes to information within the SDSs that have been provided to us by our raw material suppliers – for example, REACH registration number updates.
- There are changes that come about as a result of a change to a raw material – for example, if a raw material is discontinued.
- What is the legal position within the EU under REACH regarding notification of when a Safety Data Sheet has been updated?
Under Article 31 (9) of REACH the stipulated requirement within the EU is that:
“Suppliers shall update the Safety Data Sheet without delay on the following occasions:
- As soon as new information which may affect the risk management measures, or new information on hazards becomes available;
- Once an authorisation (REACH authorisation) has been granted or refused;
- Once a restriction (REACH restriction) has been imposed.
The new, dated version of the information, identified as “Revision: (date)”, shall be provided free of charge on paper or electronically to all former recipients to whom they have supplied the substance or preparation within the preceding 12 months. Any updates following registration shall include the registration number”.
Within this statement there are some key points of note:
- Only the changes according to Article 31 (9) of REACH give rise to a legal obligation to provide updated versions.
- There is a difference between the ‘provision of a Safety Data Sheet’ and ‘ making a Safety Data Sheet available’. For example, receiving an electronic copy of an SDS from a Magnaflux distributor represents ‘provision of a Safety Data Sheet’, whereas downloading the latest version of an SDS from the Magnaflux website represents ‘making a Safety Data Sheet available’.
- There is a difference between compliance with Article 31 (9) of REACH and the updates that Magnaflux makes to its Safety Data Sheets because of, for example, a change arising from the withdrawal and replacement of a raw material. The key difference is that, with the latter, there is no legal obligation to ‘provide’ updated versions’.
- Magnaflux sells its products via a distributor network. Using this channel-based approach, we have no knowledge of who our end-users are. For this reason, it is only possible for us to provide our Safety Data Sheets to our distributors or any direct customers of Magnaflux.
At any point where a Magnaflux SDS is updated, you will be able to obtain it: from
- your Magnaflux distributor in electronic or hard copy format.
- Via the Magnaflux website in electronic format.
If you are struggling to obtain the latest version of an SDS, please email us at email@example.com
- How do I obtain an older version of a Safety Data Sheet for a product that was made prior to an SDS change?
In most cases, the latest SDS will detail the information for the product that you have, as the changes are not normally associated with a formulation change. However, previous versions of SDSs for products are available on request by email.
In order to be able to send you the right version, you will need to provide the batch number of the product. The batch number for our aerosol products is located on the base of the can, and for our bulk products it can be found on the product label.
- How do I obtain Safety Data Sheets for products that have been withdrawn?
Following withdrawal of a product, the SDS at the time of manufacture will be available via the Magnaflux website for a period of one year. After this, any previous versions of SDSs for withdrawn products will be available on request by email.
- What language versions of Safety Data Sheets are available?
Using the Magnaflux website, you can download:
PLEASE NOTE: when using Google Translate, you – the user – accepts the legal implications of any shortcomings or differences in the translation
If you require a literal translation of a SDS in a language other than English, German or Swedish, please contact your local distributor.
- What languages do you provide on your product labels?
The issue with product labels is one of space and there are a restricted number of languages thatr can fit on the product labels. In each case, you will find six languages, chosen based on volume of products sold by country. To help provide more information,we have quoted the specific H and P references for the Hazard and Precautionary statements so you can cross-check these with the Safety Data Sheet or on the DHI website.
- What are the CLP requirements regarding product labelling?
Under the CLP regulations, a substance or mixture classified as hazardous must bear a label that includes the following elements:
- Name, address and telephone number of the supplier.
- The nominal quantity of the substance or mixture in the package where this is made available to the general public, unless this quantity is specified elsewhere on the package.
- Product identifiers – the product name.
- Hazard pictograms, where applicable.
- The relevant signal word, where applicable.
- Hazard statements, where applicable.
- Appropriate precautionary statements, where applicable.
- A section for supplementary information, where applicable.
- Hazard determining components.
- Why is there a difference between the precautionary statements listed in Section 2.2 of some product Safety Data Sheets and those found on the product label?
Under the CLP regulations, normally not more than six precautionary statements shall appear on a product label, unless it becomes necessary to include further statements to reflect the nature and severity of the hazards. The selection of the most appropriate precautionary statements is largely at the discretion and ingenuity of the supplier. Guidance on the selection of precautionary statements is given within CLP-2008-1272 Annex IV, Part 1.
What you therefore see within Section 2.2 of a Magnaflux EMEAR Safety Data Sheet is both the precautionary statements derived from the hazard classification and also supplementary precautionary statements. For the product label, it is not a requirement to list the supplementary precautionary statements as these do not directly relate to the hazards associated with the product. Typically, these relate to best practise in using the material, which is described in detail within the Safety Data Sheet – for example, in relation to the use of personal protective equipment and storage of the product.
- Are there differences between the SDSs from different Magnaflux manufacturing sites?
Yes, there are likely to be differences. Whilst GHS is a global framework for classification and labelling, it has been implemented using different ‘building blocks’ in different geographic areas. Within Europe, it is has been implemented under the CLP (Classification Labelling and Packaging) regulation (European Regulation (EC) 1272/2008).
As examples under this regulation:
- You will come across unique EUH phrases that only apply under the CLP regulation.
- European chemical classifications have been made in accordance with the European REACH regulations.