Hazardous product labelling report
May 19th 2009

The Chemical Hazards Communication Society (CHCS) has released the report of an independent review of the state of hazardous product labelling in the UK.

The report is now available free to download from the CHCS web site: www.chcs.org.uk

The report is based upon an independent and detailed examination of 50 retail products sampled from high street stores and supermarkets. The study answers two questions;

Q1. Is the packaging and labelling in the broadest sense, fit for purpose?

Q2. Is the packaging and labelling compliant with those exact requirements

that are set out in the Chemicals (Hazard Information and Packaging for

Supply) Regulations 2002 (as amended)?

The report finds that in relation to the first question, the answer was broadly yes. At least for 49 of the 50 products sampled the labelling was deemed to convey useful, adequate, relevant and sufficient information to provide for the safe use of the product as it is supplied and as it is intended to be used?

However in relation to the second question the report concludes that the labelling of leading brand products, on sale to the general public in the UK is not strictly consistent with the regulations. Given that the products were sampled from leading retailers, it is worrying that the study found substantial evidence of significant non-compliance and even in this relatively small sample, a number of potentially dangerous cases where important hazard, risk, or safety advice was missing.

The report sets out the sampling plan for the study and details the processes used to evaluate products and how the many deficiencies found were ranked and scored so as to come up with a detailed picture of the 'state of product labelling'. The main deficiencies found are identified and discussed in detail. Possible reasons for these deficiencies are identified and some recommendations are given for how compliance with product classification, labelling and packaging regulations could be improved.

The report will be of interest to all who are involved in the supply of chemical products in the UK. Also, since the UK classification and labelling and packaging requirements are based upon the EU scheme set out in the Dangerous Substances and Dangerous Preparations Directives and these are now in the process of being replaced by a version of the Globally Harmonised System (GHS), it will be of interest to the wider European community. The report concludes that the deficiencies identified by the study are largely due to the complexity of the regulations and the lack of accessible guidance. The problems faced by those responsible for specifying product labelling are set to increase as the established European system for product classification, packaging and labelling is replaced during the next few years with that completely new system that is the European implementation of GHS.

The CHCS is making this report freely available in order to increase public understanding of the issues raised.