anyone clued up on COMAH? Need to pick brains
21 May 2009, 11:13 AM
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anyone clued up on COMAH? Need to pick brains
Right here goes.
I am helping out setting up a new uk distribution centre for various different types of oils (machine/automotive/marine/offshore)
Looking at the products we will have to declare it as a COMAH site, at present it is only going to be the lower tier. I am currently going through a few thousand msds sheets to see what will fall under the comah regs, and ive hit a dead end with a particular product, so just looking for advice.
I have a product that is classified as dangerous according to Directive 1999/45/EC. (This is on the hazard ident on the msds)
The composition of ingredients indicates 2 risk phrases which are R53 and R50/R53.
Now in the regulatory info section on the msds, there is no label requirements, and the risk phrase is given as R52/R53 which I believe means there shouldnt be any labels. However nowhere else on the msds does it mention R52/R53, surely this should have been in the composition of ingredients sections???
In the next section of the MSDS Other Information, it again mentions the risk phrase of R50/R53.
Now if that risk phrase was in the previous section then it would require a orange label with the fish etc would it not???
Is this just one totally wrong msds, or am I missing something?
I have spoken with our customer (big company) and they are looking into it but as they are global there are going to be time difference involved etc.
Cheers for any replies!!
I am helping out setting up a new uk distribution centre for various different types of oils (machine/automotive/marine/offshore)
Looking at the products we will have to declare it as a COMAH site, at present it is only going to be the lower tier. I am currently going through a few thousand msds sheets to see what will fall under the comah regs, and ive hit a dead end with a particular product, so just looking for advice.
I have a product that is classified as dangerous according to Directive 1999/45/EC. (This is on the hazard ident on the msds)
The composition of ingredients indicates 2 risk phrases which are R53 and R50/R53.
Now in the regulatory info section on the msds, there is no label requirements, and the risk phrase is given as R52/R53 which I believe means there shouldnt be any labels. However nowhere else on the msds does it mention R52/R53, surely this should have been in the composition of ingredients sections???
In the next section of the MSDS Other Information, it again mentions the risk phrase of R50/R53.
Now if that risk phrase was in the previous section then it would require a orange label with the fish etc would it not???
Is this just one totally wrong msds, or am I missing something?
I have spoken with our customer (big company) and they are looking into it but as they are global there are going to be time difference involved etc.
Cheers for any replies!!
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