BCF Annual Handbook 2019/2020 handbook 2019 2 | Page 65

PARTNERSHIPS Sector wide business support Health & Safety Classification and Labelling BCF members see the health and safety of their employees and customers as paramount. The Safety Advisory Panel has provided guidance to the industry on relevant issues, such as: These past 12 months were a busy time for the CLP Panel. Work continued to lobby against the new requirements for the submission of harmonised information to Poison Centres according to CLP Annex VIII (Commission Regulation (EU) 2017/542). ECHA is developing guidance, an IT tool for submission and a new Product Categorisation System which will help in monitoring poisoning cases. The Commission workability study demonstrated that the legislation was not currently fit for purpose and would be extremely burdensome, if at all possible, for the coatings industry. • • • • • • • Legislation compliance The safe use of isocyanate-containing paints Work in confined spaces Preventing falls from tankers Storage and handling of industrial nitrocellulose Noise at work Management of change The BCF’s new PaintSafe campaign was launched, aiming to promote the safe use of paints and related products and provide best practice for decorators and other paint applicators. To date two leaflets have been produced, one aimed at professional painters and decorators and the other for professional and industrial users of isocyanate-based paints. The issuing of Safety Alerts and incident reports of relevance to the industry, both from BCF members and CEPE’s Safety Group, continued. The Panel is setting up a database of handling equipment. The annual survey of accidents was improved with the number of injuries significantly lower this year. The BCF continues its close liaison with the HSE continued through the Chemical and Downstream Oil Industry Forum and the Small Business Trade Association Forum, as well as through individual contacts. BCF ANNUAL HANDBOOK 2019/20 The preliminary findings of the DG GROW “Study on workability issues of Annex VIII CLP” identified some serious issues in the implementation of the new provisions. BCF has written to both HSE and Department of Health requesting a serious rethink on the requirements and timings pointing out that the legislation, as currently in force, would bankrupt the coatings industry. The issues stem from the inability of our sector to utilise the Generic Product Identifier to limit the number of submissions and Unique Formula Indicators (UFI) that will need to be made. The preliminary results of the study confirms that a change need to be made in the legislation to make it workable. However, there is also concern that any legal change cannot be done before the first application deadline of 1st January 2020 (for harmonized reporting of mixture for consumers use). In addition, the finalised guidance has not yet been published and the second, more useful version of the ECHA portal for submissions will not be finalised before November. This gives industry no time to prepare and make the very many submissions required. 65