and results Chemicals Office of the Republic of Slovenia CLP, Zagreb, Oct

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1 ECLIPS Inspection- methodology and results Semira Hajrlahović Mehić, LL.M., B.Sc. Chemicals Office of the Republic of Slovenia CLP, Zagreb, Oct

2 Contain Cleen network ECLIPS Project - Introductions Enforcement Results Conclusions Recommendations

3 CLEEN Network CLEEN (Chemical Legislation European Enforcement Network) Network of chemical inspectorates Forum for information exchange and it performs in collaboration with the Member States enforcement projects

4 ECLIPS INTRODUCTIONS European Classification and Labelling Inspections of Preparations, including Safety Data Sheets Conference in Vienna, September 2001, an enforcement project should be started after the implementation period of DPD Focus on the compliance of classification and labelling of preparations as well as SDS Enforcement has been performed in all participating EU countries and in some at the time accessing countries Campaign ECLIPS on basis of Austrian suggestions

5 ECLIPS GOALS To assess the compliance with the chemicals legislation To develop a harmonised European enforcement of the DPD and the SDS Directive

6 ECLIPS GOALS Reduction of risks to man and environment by achieving high quality SDS Appropriate classification and labelling of preparations containing dangerous substances Exchange of information and experience between MS to avoid differences in the way the Directives are enforced Finding enforcement strategies for each country which are suitable for its national situation Equal market conditions and competitiveness of enterprises Correct labelling of dangerous preparations as a tool to attract attention of the users (workers and general public) in order to influence the buying decision.

7 Legislative background Dangerous Preparations Directive (DPD) (Dir. 1999/45/EC, 2001/60/EC) Dangerous Substances Directive (DSD) (Dir. 67/548/EEC, 28th ATP Directive 2001/59/EC) Safety Data Sheets Directive (SDS Directive) i Dir. 91/155/EEC, 93/112/EC, Dir 2001/58/EC

8 ECLIPS Focus Focus on preparation (DPD) classified as dangerous for the environment and/or as Carcinogenic, g, Mutagenic g and/or toxic for Reproduction (CMR) containing substances with sensitising properties or substances assigned a R67 (Vapours may cause drowsiness and dizziness)

9 ECLIPS Focus Several product groups - paints and varnishes - organic solvent-based cleaning agents - detergents - preparations used for construction of buildings - photo chemicals

10 ECLIPS project and the parts of the Guidance Manual - Overview This manual Eclipsactivity Who Result Chapter 1, 2 and 3 Preparation of Eclips-project per country Eclips-focalpoint Inspectors Chapter 4.2 Checklist for preparation of company inspections Preparation of company inspections Inspectors Appointments with 5 companies Chapter 4.3 Checklist for company inspections Chapter 4.4 Checklist for follow-up company inspections Company inspections Follow up company Inspections Inspectors Inspectors Questionnaire Company data Questionnaire substance Questionnaire 1 substance Questionnaire 2 substance Questionnaire substance 10 Chapter 3.3 Project planning and reporting Country analysis company inspections Eclips-focalpoint Summary per country Reporting Eclips project Working group Eclips Final Report Eclips

11 Project Phases Preparation phase Participants, i t contacts, t definitions, iti targets t of inspections, clarifications Guidance Manual : working methods and dtools, questionnaire for collecting the results (Questionnaire I on company info, Questionnaire II on inspected product) Distribution of information to national authorities, trainings

12 Project Phases Operation phase Inspections in chosen companies following the Guidance Manual Inspections included: control of classification and labelling of preparations control of Safety Data Sheets support and information for the companies During this phase first results and problems presented and During this phase first results and problems presented and discussed at the 4 th CLEEN Conference in Brussels in 2003.

13 Project Phases Reporting Phase Compilation and analysis of the more than 1500 inspected products Final report draft by MS working group

14 Participating Countries Country Norway Greece Latvia Slovenia Ireland Belgium Sweden Austria Poland Finland Spain Germany No. of inspected products Total: CLP, Zagreb, Oct

15 Participating Countries Even the operation phase was before the accession of the new MS, three of them took part in the whole project Netherlands situation CLP, Zagreb, Oct

16 Company data Category: Chemical industry: 56% Trade company: 12% Retail trade: 32% Company size: <10 : 28% : 100: 51% >100: 21% Data without Germany due to different kind of reporting

17 Preparation data Paints and varnishes: 35% Cleaning agents. 18% Re-construction: 17% Detergents: 12% Photo chemicals: 2% Other: 13%

18 Results Results on the quality of classification and labelling and SDS taken from the questionnaire No discrimination has been made between severe or minor deficiencies Statistics of the degree of deficiencies over the 10 years (Sweden)

19 Results Product with no error % OK C&L 40% SDS 31% All endpoints 22% CLP, Zagreb, Oct

20 Results - C & L Deficiencies Chemical name of the substances Danger symbols Classification Risk-phrases Safety advice Contains elements hazardous for environment Contains sensitising substances Incomplete name, substances name missing Wrong or missing symbol, wrong shape or colour Could be wrong or missing symbol, R-phrases, indication of danger Wrong or missing R-phrases Wrong or missing S-phrases Wrong environmental classification such as wrong R phrases, symbol missing Special phrase missing: Contains (name of sensitising substance). May produce an allergic reaction CLP, Zagreb, Oct

21 Results SDS Deficiencies Availability of SDS Missing or not delivered Heading 2 Substances Substances missing, i wrong classification for substances, bt incorrect chemical name, or concentration of substances Heading 3 Danger Wrong classification, R-phrases missing, poor info Heading 7 follow up Heading 8 follow up Heading 11 Too limited info, irrelevant instructions, specific uses missing, handling info missing Respiratory protection equipment should be announced more specified, Insufficient type of protection equipment, personal protection measures missing Only data given summary and symptoms description missing, too limited; LD 50 does not tell enough to the user. Sensitizers ers info missing. CLP, Zagreb, Oct

22 Results SDS Deficiencies Heading 12 Heading 15. Data and effects missing, Conclusion missing Wrong classification, R- and S-phrases missing Correspondence Heading 15 - label Different classification, R- or S- phrases is given in label compared to heading 15. CLP, Zagreb, Oct

23 Results - Correlations Clear correlation concerning the deficiencies: the bigger the size (no. of employees) of a company the better the quality of the data Companies with implemented the ISO system have less deficiencies in data than others Data from companies that are members in trade organisations have a slightly better quality than data from others. There is still work to do for the trade organisations. CLP, Zagreb, Oct

24 Conclusions All countries have improved their level of information on the enforcement and compliance of the Directives, in own countries and in relation to other EEA countries The provisions of the mentioned regulations have been enforced, by all participating countries, in a co-ordinated way Harmonization of inspections by using the same working method Identification of common problems in the implementation of the Directives (FAQ) CLP, Zagreb, Oct

25 Conclusions The sharing of experiences will lead to more effective and efficient future enforcement Improvement of awareness of the preparations and SDS in industry Improvement of tools for enforcement Annex I of the Dir. 67/548/EEC has proven to be the most relevant tool for the inspectorate in the enforcement of the classification, labelling and SDS of dangerous preparations CLP, Zagreb, Oct

26 Recommendations Annex I should keep its actual mandatory status as the main tool for companies and enforcers regarding the harmonization of the classification and labelling ECLIPS Project has brought up the need to have a Guidance Document or a Manual of Decisions Future CLEEN projects: SDS as the tool for information flow down the supply chain (REACH) CLP, Zagreb, Oct

27 Inspection campaign ECLIPS examples Slovenia Producers and importers of paints and varnishes 44 products inspected, 10 companies Results similar to average presented (except SDS) CLP, Zagreb, Oct

28 Thank you!