March 23, 2023
By Susana Planas MunGavin, BSc, MSc, regulatory specialist, Supply Chain Team, UL Solutions
In March 2023, the Health and Safety Executive (HSE) released two new Technical Reports for herbicide S-Metalochlor (CAS No. 87392-12-9) and the industrial use chemical, Peracetic Acid (CAS No. 79-21-0). This followed eight Technical Reports published in February 2023, addressing other substances, including the biocidal active substance, Formaldehyde (CAS No. 50-00-0), the active substance in plant protection products, Glyphosate (CAS No. 1071-83-6 ) and six other specific substances for which GB mandatory classification and labelling (GB MCL) criteria are being proposed based on scientific and technical assessments. Each of the Technical Reports include an overview of the existing hazard classification entries as approved under the GB MCL list compared to Annex VI of Regulation (EC) No 1272/2008 on classification, labelling and packaging (EU CLP) of substances and mixtures. For example, the assessment of Peracetic acid (PAA) includes the consideration of the following hazard classes, which were also included in the EU harmonised classification and labelling (CLH) report and Committee for Risk Assessment (RAC) Opinion: flammable liquids, organic peroxides, acute toxicity (oral, dermal and inhalation routes) and hazardous to the aquatic environment. This substance has an existing hazard under the GB MCL which includes Skin Corr. 1A. Skin corrosion has not been assessed in the technical report, therefore Skin Corr. 1A continues to be retained in the GB MCL. PAA is a registered substance under the EU REACH regulation and is manufactured in, or imported into, the European Economic Area in quantities in between 1000 and less than 10000 tonnes per annum. The substance is used by consumers and by professional workers for a number of uses, such as in formulation and repackaging at industrial sites and in manufacturing.
The classification and labelling of substances and mixtures placed on the market in Great Britain must comply with the criteria set out under the GB MCL. The GB MCL retained EU harmonized classification and labeling criteria in force in the European Union until December 31, 2020. Since then, a total of 177 Technical Reports have been published by the HSE in order to propose new and updated classification and labeling criteria, as deemed appropriate. Technical Opinions have followed most reports. A total of 128 have been published. The last eight were released in February 2023, addressing widely used chemicals, such as Potassium chlorate (CAS No. 3811-04-9), Triethylamine (CAS No. 121-44-8), Di-n-butylamine (CAS No. 111-92-2), and Sodium chlorate (CAS No. 7775-09-9).
Final classification and labelling decisions will be implemented by the HSE in the revised GB MCL within 12 months of publication of the Technical Opinions and following any further classification recommendations made to the Secretary of State (ministers). HSE may introduce GB MCL changes once a year based on the concluding GB MCL Agency Opinions. The final ministers' decision and consent of the Devolved Administrations (Scotland and Wales) is required for the GB MCL List to be updated, and the effective date of the decision concerning the substance new or revised entry into the MCL is established.
A full list of GB MCL technical reports is available on the HSE MCL Excel Table.
Recommended action items
- Review the list of substances included at the end of the GB MCL Excel table.
- Ensure substances are being used or handled at the workplace in accordance with the new and updated classification.
- Review associated substance documentation, such as SDSs and labeling.
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