The information provided by supplier’s is the main way most users have a chance of finding out about the hazards presented by the substances they use. Occupational hygienists and safety professionals often focus on the MSDSs (material safety data sheets) but the label is often a much more useful source of information. If compiled correctly it should indicate, at a glance, the principal hazards and provide a summary of the main concerns.
Dangerous substances and preparations sold or imported in the European Union have to comply with the requirements of the Dangerous Substances Directive and the Dangerous Preparations Directive. In Great Britain these Directives have been implemented as the Chemicals (Hazard Information and Packaging for Supply) Regulations 2009 (CHIP).
While I was out on a walk a few days ago I spotted a sack of “Macadam” and couldn’t help but notice the label. Here’s a close up.
At first glance it looks like a standard CHIP label. It features the black diagonal cross with the hazard classification “Irritant” printed boldly on it. However, the rest of the information does not comply with CHIP. It should use the standard R and S phrases to provide the user with information on hazards and precautions that should be taken. However the wording on the label doesn’t comply with this.
Looking at it in more detail, under the heading “Main Hazard” it doesn’t provide any hazard information at all. Instead it advises “avoid use in confined space and inhalation of fumes”.
The heading on the label is “Health and safety warning (COSHH 1987). Well, first of all COSHH does not place any duties on suppliers. As I’ve already mentioned in Great Britain its CHIP that is applicable. They’ve also made a mistake regarding COSHH. These Regulations were first enacted in 1988, coming into force in 1989. There have been major revisions with newer Regulations replacing the original ones. The current COSHH Regulations being dated 2002 (although there have been some major amendments to these). So the title is out of date. In fact, even worse than that, there weren’t any COSHH (1987) Regulations.
The format and content of the label indicate that the supplier doesn’t understand the law on labelling. It doesn’t give me much confidence that they understand the hazards their product presents either.