Becoming GHS compliant (English)

Our customer had to be compliant with a new European regulation on classification, labelling and packaging of substances and mixtures (CLP) as part of the alignment to the Globally Harmonised System of Classification and Labelling of Chemicals (GHS). The aim of this system is to ensure a better protection of human health and the environment during the handling of chemicals, including their transport and use.

Our mission as Project Manager (co-lead with Head Global Environment, Health and Safety), was to make sure that our client comply with GHS classification and labelling system in accordance with local/regional legal implementation deadlines with minimal disruption to the business.

Our main responsibilities were to define the scope, and then to plan, execute and implement the agreed solution; some of the main deliverables were:

• Ability to perform the new GHS calculations (determine new classification)
• Ability to print the new GHS labels in all European factories and relevant laboratories
• Ability to create the new Safety Data Sheet (SDS) worldwide

Together with our customer, we found a pragmatic solution within cost constrains (e.g. no need to buy new printers) and low complexity in business process and systems (e.g. implement similar labels for substances and mixtures at the same time). Communication was a real challenge, several different audiences received different messages, e.g. new labels are used only in Europe, SDS is used globally except North America, some Asian factories are using the same GHS data but different labelling system, GHS implementation deadlines varies by region/country, etc.

The outcome was that our customer implemented the CLP regulation (European GHS) for substances and mixtures before the legal deadline. It is important to mention that project was concluded on time without disruption to normal operations and that stabilization phase was very smooth. A roadmap for GHS implementation in the rest of the world was delivered, and efforts to adapt other systems to support the new regulation were initiated.

Beyond the original scope, we helped our customer to rationalize the number of label suppliers in Europe; this facilitated a more uniform labelling of their products as well as to reduce costs.

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