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KMID : 1039220150250020115
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Journal of Korean Society of Occupational and Environmental Hygiene
2015 Volume.25 No. 2 p.115 ~ p.125
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How to Improve the Reliability of MSDS and Labels?(2): A Review on the EU CLP(REGULATION(EC) No 1272/2008)
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Kim Shin-Bum
Lee Yun-Keun
Chou Young-Eun
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Abstract
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Objectives: The major objectives of this study are to review the EU CLP Regulations to propose ways of improving the reliability of MSDS and labels.
Methods: To review the EU CLP Regulations, we used EU documents including directives and regulations on chemical management. In addition, we used EU governmental agency reports to illuminate the history and background of the CLP. We found the EU CLP`s instruments for reliable hazard communication and evaluated the operations of the instruments.
Results: EU CLP Regulations have four instruments for the EU CLP Regulations to make hazard communication reliable. These instruments are GHS, the harmonized CMR and respiratory sensitive substances classification list, C&L inventory and restriction of trade secrets. These are highly useful for achieving the objectives of REACH and CLP(no data-no market and changing the burden of proof).
Conclusions: Changing the burden of proof is a key principle for achieving a society safe from hazardous chemicals. Chemical manufacturers and importers alone should bear the responsibility for reliable MSDS. We recommend benchmarking the EU CLP Regulations in order to change efficiently the burden of proof. Trade secrets should be limited to low-hazard substances and be approved by the government before the chemical product is on the market. Like the C&L inventory, chemical product information including substances identification and hazard properties should be notified, aggregated and be opened to public on the Internet. Finally, we recommend a MSDS registration system once again.
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KEYWORD
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C&L inventory, EU CLP, GHS, MSDS, trade secret
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