ECJ EUROPEAN Cleaning Journal

Supplying and transporting potentially hazardous cleaning substances requires accurate labelling to adhere to strict European legislation. James Killerby, director of Hibiscus, supplier of bespoke labels, warning diamonds and software solutions for the chemical and transport industries, explains the legislation and what to look for in labelling products.

Detergents, disinfectants, bleach and sanitisers are just some of the potentially harmful products used in the cleaning industry. Clear labelling is crucial to help prevent accidents and to provide speedy medical help should one occur.

Universal labelling of hazardous materials in transport gives emergency crews vital knowledge of what action to take in the event of a collision: whether to use foam or water, what protective gear to wear and whether, in extreme circumstances, to evacuate the area. Legal documentation for transporting both hazardous and non-hazardous substances needs to be considered too.

The legislation relating to correct labelling is complex and changes frequently and there are a wide variety of regulations and laws to consider when designing your labels.

The CLP Regulation (Classification, Labelling and Packaging of Substances and Mixtures) came into force in January 2009. Companies had until December 1 2010 to ensure that any labels for single substances were updated to the new regulations and, by  June 1 2015, must do the same for mixtures.

Its purpose is to protect people and the environment from the effects of hazardous chemicals by requiring suppliers to provide information about the dangers and to package substances safely.
All over the world there are different laws on the classification of chemicals and how information about these hazards is passed to users through labels and safety data sheets. The same chemical can have different classifications in different countries so, to avoid confusion, the UN brought together experts from different nations to create the Globally Harmonised System of Classification and Labelling of Chemicals (GHS).

The aim of GHS is to apply the same criteria for classifying chemicals worldwide, according to their health, environmental and physical hazards and the subsequent requirements for labelling and safety data sheets.

The UN GHS is not a formal treaty, but a non-legally binding international agreement. Therefore countries (or trading blocks) must create local or national legislation to implement GHS.  CLP is the legal document that applies in Europe.

CHIP (Chemicals Hazard Information and Packaging for Supply) is the law that has applied to suppliers of dangerous substances and mixtures for many years and will continue to be applied to mixtures until their reclassification to CLP on June 1 2015.

Transportation

When it comes to the transportation of hazardous cleaning substances, vehicles, rail carriages, pallets and packages must all be labelled.  The regulations covering the transport of dangerous goods are very different from those covering supply although, with the implementation of CLP, some of the differences will diminish. There are also separate arrangements for road, rail, air and sea.

Journeys by road through Europe are covered by the ADR Regulations. Kemler ADR panels on the side of the vehicle identify the hazardous substance being carried and how to respond in the event of an accident. Labelling companies will be able to supply either pre-printed or modular systems which comply with legislation in terms of weathering and ADR reflectivity requirements.
Rail movement is covered by RID (Regulations concerning the International transport of Dangerous goods by rail (European Law) for Rail.

Free movement

Air transportation is dealt with by the ICAO (International Civil Aviation Organisation) Technical Instructions for the Safe Transport of Dangerous Goods by Air. Anyone transporting dangerous goods by air should also check the IATA (International Air Transport Association) Dangerous Goods Regulations as these contain additional requirements.

The transport of dangerous goods by sea is governed by the IMO (International Maritime Organisation) International Maritime Dangerous Goods Code (IMDG). The UK Maritime and Coastguard Agency website also contains useful information about dangerous goods.
REACH is an EU regulation concerning the Registration, Evaluation, Authorisation and restriction of Chemicals. 

It is intended to make manufacturers and importers responsible for understanding and managing the risks associated with their use.  It also helps to allow the free movement of substances on the EU market and enhances innovation and competition within the EU
chemicals industry.

When it comes to chemical labelling, there is no ‘one size fits all’ approach. The specification you need depends on so many factors – from the surface onto which the label will be stuck, to the part of the world it will eventually be.

There are three parts of your label that you need to consider – the face, the backing and the adhesive. And just because one part is right, doesn’t mean the whole label complies to standards. You could use the correct adhesive on office paper for example and it would just wash off – it is the combination that has to be correct. Some adhesives don’t work well some face materials – emulsion acrylic works better on PE better than PP for example. Focus on the whole combination of the label and adhesive or you might find you have spent a significant amount of money on something that is essentially illegal.

Consider adhesives

Look out for different types of adhesive – increasingly they tend to be emulsion acrylics rather than solvent-based adhesives. The amount of solvents used by businesses is significantly lower than it has been in the past due to a government drive to reduce the risk to the environment.
Before commissioning your label, think about what it will be expected to withstand. What will its life cycle involve? Where will it go? What will it be exposed to? Changes in temperature and humidity need to be taken into account.

Lastly, think about when you will apply your label. If, for example, you stick it to a drum and then immediately fill it with a hot product, the surface will expand. If you then take it out into a cold yard it will shrink back quickly, which could lead to some label materials becoming wrinkled or even coming off completely.

There is an adhesive product that will stand that extreme variation in temperature but it is more expensive as it’s a higher specification. The most expensive consideration you might have is your production time so this product would be appropriate for fast and dynamic processes.

The most important thing is that your labelling company knows all this when they come to create the label. We  like to do a site visit with all our clients so we can see their processes at first hand. It helps guide us to use the most appropriate materials.

Top tips

•    Prepare the surface before you put your label on – make sure there is no moisture on it and your label will stick better.
•    Stick down all the parts of your label carefully rather than just slapping it on.
•    Don’t stick your label to anything else before the surface it was designed for.
•    Ask yourself what the label’s life cycle will be and what it will be exposed to. If you don’t know, it will be poorly specified and might not look as good or stick as well as it could have done.
•    Make sure that the ink you use to add the variable information onto your label is right for the material – for example, wax resin ribbons work better on matt label surfaces.

Every business is unique and the labels that are needed can serve very different purposes. Take time to think about your labels. A couple of minutes’ care could save your business cost and reputation in the long term.

www.hibiscus-plc.com