GHS RESPONSIBLE PRODUCT STEWARDSHIP. Houghton International Product Stewardship Preparing for GHS in Europe

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1 RESPONSIBLE PRODUCT STEWARDSHIP Houghton International Product Stewardship Preparing for GHS in Europe Moving Towards A World-Wide System For Communicating Chemical Hazards In The Workplace. As a global market leader in the metalworking fluids business, Houghton International, Inc. has proactively taken steps to ensure timely compliance with the U.N. Standard for the Globally Harmonized System (GHS) for Classification and Labelling of Chemicals. This includes compliance with the European Classification, Labelling and Packaging (CLP) legislation. The information provided within this brochure is for reference purposes only and reflects Houghton s understanding and the actions underway to address GHS-related regulations for Europe. We actively encourage our customers and distributors to consult with their own regulatory advisors and legal counsel regarding any specific actions they may need to take. During the transition phase, our sales professionals and regional experts in product safety and regulatory affairs are available to answer your questions regarding our products and compliance with GHS. Please ProductStewardship@houghtonintl.com What Is GHS? The primary purpose of the Globally Harmonized System (GHS) is to standardize the classification and labelling of hazardous chemicals to aid in the communication of critical chemical safety and handling information including the use of internationally recognized pictograms on Safety Data Sheets (SDS) and container labels. GHS is an international mandate developed by the United Nations in 1992 with the intent that individual countries around the world adopt the standard as a part of their regulatory process for managing hazardous chemicals. GHS is structured to improve worker understanding of hazards in the workplace and to reduce barriers to international trade. GHS World-Wide GHS is neither a global law nor regulation. It is a system or a set of recommendations that utilize a building block approach. No country is obligated to adopt all or even any part of GHS elements. Countries are free to determine which of the building blocks they will adopt but the portions of GHS that are adopted must follow the GHS standard. June 1, 2015 Timeline: Europe United States Canada pending Mexico not mandatory Brazil Singapore Several countries have already implemented GHS while others have later deadlines or have not yet adopted GHS. GHS The Globally Harmonized System of Classification and Labelling of Chemicals 1

2 December June June 1 Initiate GHS training for all employees Manufacturers and distributors reclassify and update labels and SDS for substances in GHS format Manufacturers and distributors reclassify and update labels and SDS for mixtures in GHS format Compliant GHS format SDS and labels for all existing stock in the supply chain CLP Implementation Timeline CLP vs. GHS The CLP legislation has adopted portions of GHS. CLP incorporates the GHS criteria and provides a new method for classifying chemicals based on their health and physical hazards. Not all regions have adopted all criteria, including Europe. For example, CLP has not adopted all of the criteria for combustible liquids. Manufacturers are still required to classify chemicals (using newly adopted GHS criteria), provide these SDS to customers and provide proper product labels. Employers are still required to have a hazard communications plan, conduct employee training, maintain copies of SDS for chemicals used in the workplace and properly label all hazardous chemicals. Houghton International will be providing GHS-compliant SDS and product hazard labels using CLP. As always, our SDS and labels will be provided in a range of languages depending on the location shipped. By June 1, 2015, GHS-compliant SDS and product labels will be in use for all active products sold by Houghton International in Europe. What Are The Key CLP Deadlines? Under CLP, all employers were required to initiate training for their employees on the new label elements and SDS format no later than December 1, Manufacturers, distributors and importers were required to reclassify and/or provide updated SDS and product labels for all substances in the GHS format as of December 1, Updated SDS and labels in GHS format will be required for mixtures from June 1, There is a transition period for existing stock of 2 years up to June 1, Finally, employers are required to be fully compliant with GHS for inventoried products including updating alternative workplace labelling and hazard communications plans. Employers must also provide additional employee training for newly identified health and physical hazards identified on the SDS. Who Is Affected? If you manufacture, import, distribute, transport or use hazardous chemicals, you will be affected. GHS covers all hazardous chemicals without exception. The term chemical is used broadly to include substances, products, mixtures and preparations. All chemical manufacturers, importers and distributors who are subject to CLP will need to adapt to the new GHS-based rules. 2

3 What Hazards Do The New Pictograms Represent? How Will Product Hazard Labels Change? The information on the labels will become standardized to increase employee comprehension of the potential hazards and precautions related to the chemical product in each package or container. The standardized label elements include: 1. Hazard symbols called PICTOGRAMS (shown above) represent health, physical and environmental hazard information. There are nine pictograms that are assigned to 28 different GHS hazard classes and categories. The 5 pictograms outlined in yellow are those most commonly used for metalworking fluids. 2. SIGNAL WORDS Danger or Warning are used to emphasize the relative level of severity of the hazard assigned to each GHS hazard class and category. 3. HAZARD STATEMENTS: Standard phrases assigned to each hazard class and category that describe the nature of the hazard. 4. PRECAUTIONARY STATEMENTS: Describes the recommended measures to minimize or prevent adverse effects resulting from exposure including prevention, response, storage and disposal. 5. It is still required that the product name (same as SDS), the name, phone number and address of the manufacturer, distributor or importer (responsible party) are included on the container label. 3

4 Will Workplace Labelling Change? Products falling within the scope of GHS will have GHS labels at the point where they enter the workplace. The GHS label or label elements can also be used for workplace containers. However, employers can also choose to communicate information using alternative methods where chemicals are transferred from supplier containers to containers for laboratory testing, storage vessels, piping or process reaction systems; or temporary containers where the chemicals will be used within a short time frame. Where national workplace legislation covering labels exists, alterative workplace labels should be in compliance with those requirements. How Will Safety Data Sheets Change? CLP SDS follow a standardized 16-section format similar to previous legislation. The SDS will continue to provide hazard and precautionary information about a chemical substance or mixture. The primary purpose of the SDS is to provide employers/employees with information to support the evaluation of workplace hazards and appropriate safety precautions. Under GHS, the SDS will specify the hazard class and category for the substance or mixture. For each hazard class and category, the SDS will identify prescribed/mandated hazard statements, pictograms and precautionary statements. Our Approach Houghton International Inc. is a global market leader in metalworking fluids and related value added technical services. Metalworking fluids (MWF) are missioncritical specialty chemicals used for metal removal, heat treatment and quenching, rust prevention, specialty hydraulics, rolling oils and related applications. Houghton employs a wide range of chemicals and additives in the manufacture of our metalworking fluid formulations. This allows us to offer a broad product line with many options to meet customer specific as well as region/country specific EHS and/or regulatory requirements. We have many product options that are non-hazardous and/or do not contain raw materials that may have mixed acceptance in certain regions/ countries. Houghton routinely reviews these materials as new information and data is made available. As part of our product stewardship commitment, we continue to make EHS a priority in our planning for new and existing products and actively counsel customers on the safe use, handling, transport and disposal of our products. Old Pictograms (DSD/DPD) Explosive (E) Extremely (F+) and Highly Flammable (F) Oxidizing (O) Very Toxic (T+) and Toxic (T) Corrosive (C) To eyes or skin Harmful (Xn) or Irritant (Xi) Dangerous for environment (N) New Pictograms (GHS/CLP) 4

5 Our Commitment CUSTOMER FOCUS EHS FOCUS Here at Houghton, we are committed to meeting all environmental, health and safety and product regulatory requirements in the markets we serve including GHS. Our broad and deep product portfolio provides many options that allow us to meet application/performance, regulatory, EHS and other requirements for our customers world-wide RECEPTIVE TO CHANGE GLOBAL TEAM PLAYER RESULTS DRIVEN INTEGRITY Ria Scheuren Vice President, EHS & PS OPEN COMMUNICATION INNOVATIVE Will ADR Transport Pictograms Change? For transport, existing transport pictograms will be used and will maintain the background and symbol colours currently used. Where a transport pictogram appears, the GHS pictogram for the same hazard should not appear. It is important to note that changes in hazard classification under GHS may impact the classification under other related regulations (e.g., corrosive under GHS = corrosive under Dangerous Goods/ADR). 5

6 Will GHS Have Any Impact On The Chemical Composition Of Houghton Products? Houghton is not changing product formulations as a result of GHS. Under GHS, the classification system has changed, resulting in different, often lower thresholds and hazard criteria. Suppliers of raw materials are also providing updated and detailed information as a part of their preparation for GHS. It is possible that the classification of some products may change. Houghton has no plans at this time to discontinue use of any of its raw materials or products as a result of GHS. Houghton does routinely evaluate its raw materials and product formulations and may modify or discontinue products when versions with better performance, quality, cost, consistency and EHS can be achieved. What Can You Expect From Houghton? Houghton is committed to helping our customers and distributors understand GHS. We have followed the GHS rulemaking since it started and our product safety and regulatory affairs experts have been involved with organizations to help shape GHS implementation. We will support our customers and distributors by: Properly classifying our products Making sure our product SDS, labels and marketing materials meet GHS requirements Training our sales and technical service representatives so they can help you understand GHS and answer your questions Direct access to SDS via a customer web portal by June 2015 How Can I Learn More About Houghton s European Implementation? If you have any questions about Houghton s GHS implementation in Europe, please contact your local Technical Sales Representative or our Product Stewardship Team (ProductStewardship@houghtonintl.com). You can also visit our website at Where Can I Get More Information About GHS And CLP? To learn more about GHS and CLP, please visit: United Nations: org/trans/danger/publi/ghs ECHA: Contact Us Houghton PLC Beacon Road, Trafford Park Manchester MI7 IAF United Kingdom Tel: +44 (0) Fax: +44 (0) uk.enquiries@houghtoneurope.com productstewardship@houghtonintl.com (for specific GHS inquiries) HI GB 6