EU Classification - Directive 67/548/EC
These changes to the current practice require the attention of the customers in several ways. The new classification results in a new hazard class (environmentally hazardous, N, R50-53) in the regions, which are impacted by the EU classification system. It results at the same time in a new transport classification as dangerous goods class 9, UN3077, PG III, Environmentally hazardous substance, solid, n.o.s. for those countries and regions following the ADR/RID/ADNR (*) transport regulatory system.
These new classifications can have an impact for the receiving parties on storage conditions, permit conditions or reporting requirements to authorities. This has to be checked by the customers in the local regulatory systems.
These new classifications have impact on the delivery conditions for Umicore and on the hazard communication in general.
Procedures for the classification, packaging and labelling in the EU are outlined in Directive 67/548/EEC for dangerous substances and in Directive 1999/45/EEC for dangerous preparations.
The directives are concerned with identifying hazard, not risk. Through Safety Data Sheets and labelling processes they establish an effective information transfer from producer/supplier to customer so that the degree of hazard the chemical presents for man and the environment can be recognised, the correct preventive actions be taken and safe use of the chemical achieved.
Similar regulatory systems exist in other countries in the world.
The main substances in our product are recently both classified as Very Toxic to the Aquatic Environment (N, R50-53) in the EU classification system. This new classification was published in the Official Journal of the EU on 30 April 2004 (Commission Directive 2004/73/EC) and the Member States shall bring into force the necessary provisions to comply with this classification by 31 October 2005.
Since zinc powder / zinc dust and also zinc oxide are classified as N, R50-53, Very toxic for the aquatic environment, the preparations are to be classified in the same way following the rules of the preparations directive.
For transport, provisions to test the material and to deviate from listed classifications are available. Based upon the test results, the materials are not to be classified as Dangerous Goods in class 4.1, 4.2 or 4.3.
Taking the new classification (ecotoxicity) under the preparations directive into account, the transport regulations ADR/RID/ADNR stipulate that the different commercial grades to which the letter ‘N’ have been allocated will become dangerous for transport. They are to be classified as Dangerous Goods, UN3077, Environmentally Hazardous Substance, solid, n.o.s.. Shipping according to these regulations requires specific packaging (UN certified), labeling (see separate ecotoxicity label) and transport modes (ADR regulations – see separate transport label).
The fact that these materials are classified as very toxic for the aquatic environment, N; R50-53 has also an impact on the permit conditions in warehousing and in production areas. The Seveso directive in the EU has limit values from which specific previsions have to be taken and reporting requirements apply. The trigger limits are 100 and 200 tons of material in storage (including process storage).
As soon as you are above one of those limits you should investigate the consequences with the local authorities if you are under the EU regulatory system.
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(*) ADR = European Agreement concerning the international carriage of Dangerous goods by Road
RID = Regulation concerning the International rail transport of Dangerous Goods
ADNR = European Agreement concerning the international carriage of Dangerous Goods on the Rhine and Belgium)