The register as guiding principle
Numerous substances and preparations are purchased and used at the UMC on a daily basis. But does a substance or mixture qualify as a dangerous substance or not? And what rules apply when working with the substance? Nobody knows all the rules by heart. Therefore, do the following when you purchase a new substance.
- Check whether a substance or preparation qualifies as a dangerous substance.
To this end, you can consult the following sources:
- the national NFU dangerous substances database of the joint UMCs;
- the dangerous substances register that every UMC is required to have in its possession;
- the supplier who is obliged to supply a material safety data sheet (MSDS) with every first delivery; - your OHS advisor.
- Based on the risks involved, determine whether all necessary procedures, instructions and facilities are in place, such as the appropriate storage facility, an extraction facility, a specific containment level and the necessary waste flow facilities. If this is not the case, take the necessary measures. If you do not know what these are, please contact your OHS advisor.
If you are already using substances that are not in the register, have them included.
The less the better
The following applies prior to the purchase of a dangerous substance:
- Check whether replacement with a less dangerous substance is possible;
- Do not order more than is strictly necessary;
- Always order through the appropriate channels;
- Assess whether, in the case of small quantities, you can use stocks from other departments;
- Do you need a permit for the dangerous substance;
- Are there any other statutory requirements, such as:
- Are there any requirements in the context of CBRN, such as dual-use substances, precursors to explosives.
If you wish to use Substances of Very High Concern (SVHC), you are obliged to replace them with less hazardous alternatives if this is technically or medically possible. SVHC substances include carcinogenic, mutagenic or reprotoxic (CMR) substances, substances that are (very) persistent, bioaccumulative and toxic (PBT or vPvB). The current list of SVHC substances can be found via the search system of the RIVM (Dutch National Institute for Public Health and the Environment).
The label as a guide
You cannot tell from a substance or mixture what it is and whether it is dangerous. That is why the labels on the packaging are so important. If a label does not meet the requirements or if there is any doubt about the contents of the packaging, please contact the supplier.
Two types of labels
Before January 2009, the basic principles of the hazard label were laid down in two European directives, the Substances Directive and the Preparations Directive. The CLP Regulation has been in force since January 2009.
The abbreviation CLP stands for Classification, Labelling and Packaging of substances and mixtures. This Regulation ensures the introduction of global agreements on the harmonised system for the classification and labelling of chemicals and mixtures based on hazard properties.
The global system is called the Globally Harmonised System (GHS. The European variant of the GHS is the EU GHS. The new rules for single substances have been in force since 1 December 2010. For mixtures, the classification will be applied from 1 June 2015. Both regulations are subject to a transitional period.
From 2012, single substances are no longer allowed to have old labels. Dangerous substances in the form of mixtures are allowed to bear the old orange labels until 1 June 2017. For additional information, see the Safety Information / Labelling section.
The new mandatory hazard pictograms are black pictograms placed in a red bordered white diamond. In addition to the pictograms, the label contains the so-called new H and P phrases, which have replaced the old R and S phrases.
- H phrases (Hazard, hazard statement).
- P phrases (Precautionary, precaution / safety recommendation).
- The signal word 'Danger' or 'Warning'.
- Any additional information.
The old mandatory hazard symbols are black with an orange/yellow background. These labels are replaced by the new GHS labels. The label contains the R and S phrases in addition to the symbols.
- Risk(R) phrases. (See Appendix 2 Risk and Safety Phrases for more information);
- Safety(S) phrases. (See Appendix 2 Risk and Safety Phrases for more information);
- Special hazard statement (e.g. 'Caution: contains lead’).
Labels must meet the following requirements:
- They must be affixed indelibly, prominently and clearly legibly;
- The language used on the label is normally Dutch. Laboratory substances in a container of less than one litre may bear a label in English, German or French.
The label must feature:
- The name, address and telephone number of the supplier;
- The nominal quantity of the substance or mixture, unless the quantity is specified elsewhere on the package;
- The product specification: the name of the substance and a so-called identification number;
- Where applicable: hazard pictograms, signal words, hazard statement, precautionary statements and a section containing additional information.
Filling, repackaging, lines, etc.
- The above requirements also apply to filling from large to smaller containers and to self-formulated solutions for general use. This takes place at the pharmacy and in laboratories;
- Different rules apply to the repackaging or formulation of solutions for individual use;
- Labelling and signalling of reservoirs, pipes and fill and tap points can be found at 'Storage'.