Fold out labels, also known as booklet labels or extended content labels, are commonly used for the labelling of products for identification and branding purposes. However, when it comes to labelling potentially dangerous chemicals, these type of label can raise serious issues of suitability, fitness for use, and compliance.
EC Proposal
The European Commission recently presented its proposal for a revised regulation on the Classification, Labelling and Packaging of chemicals (CLP Regulation). Part of the proposal seeks to improve the communication of chemical hazards through simpler and clarified labelling requirements. The proposal introduces minimum font sizes and line spacing for text – which would mean a vastly reduced area available for the label content – and simultaneously, aims to allow for the broader use of fold-out, multi-lingual, labels in order to allow the industry to take advantage of ‘economies of scale’. The proposal also introduces rules for voluntary digital labelling which allows for selected supplemental information only to be included on the digital label.
Areas for Concern
Normally, a chemical label is affixed directly to surface of the container, such as a bottle or drum, however, if the labelling information required by law exceeds the available space on a small, or awkwardly shaped container, then a possible solution to increase the available space is to use fold-out labels, especially for a product sold across numerous countries requiring multiple languages to be included on just one label.
Fold-out labels are a concertina or booklet design, with information contained within the folds. The part of the label that is affixed to the container must must be done so by use of a strong and permanent adhesive as this is the part that should contain the necessary content that is required by law: the pictograms, the product identifier, the hazard and precautionary statements, and the name and telephone number of the supplier. These details would remain attached to the container if the rest of the fold-out label is torn away – however, this does not help if the remaining part of the label is not in the corresponding language of the user.
The front page (the part on display on the container) should repeat this information, and in addition show: the name of the supplier; the nominal quantity (if sold to the general public); and a phrase to indicate that further safety information is available in the fold-out section – which should be translated (and accompanied by the country code letters) in all languages contained in the fold-out label. The booklet part of the label is designed for use with REMOVABLE adhesives and is not permanently stuck to anything. The only part of the label that would meet part 2 the BS5609 requirements would be the part that is stuck to the drum, or container – the rest of the label is simply not stuck to anything!
Issues for the Industry
- Durability: Fold-out labels can easily become detached or damaged due to accidents and wear-and-tear – making it difficult to identify the contents of the container in case of an emergency and potentially exposing workers to hazardous substances.
- Chemical Resistance: Fold-out labels may not be resistant to harsh chemicals, leading to fading or dissolving of the label, making it difficult to identify the contents which is a critical issue when labelilng hazardous substances.
- Lack of Legibility: The small size of the text on fold-out labels can make it difficult to read important information such as warnings, first-aid measures, and handling instructions. The small print can be difficult to read, especially in low-light conditions, making it challenging to identify the contents of the container and could lead to misinterpretation or misapplication of instructions, which can be dangerous in the chemical industry.
- User Experience: Fold-out labels can be complex and difficult to read, which can lead to confusion among users. This can be especially problematic in situations where users need to quickly understand the product’s instructions or safety warnings. Pull labels can be difficult to use, especially for those with limited dexterity, visual impairments, or employees wearing gloves – which may be a necessity for certain substances.
- Compliance: Many countries have regulations that require specific information and symbols to be displayed on labels for dangerous chemicals, which may not be possible to fit on a fold-out label. The booklet part of the label uses adhesives that would not comply with part 2 the BS5609 requirements.
- Cost: Pull-Out labels can be expensive to produce, as they require additional materials and printing processes. This can be a significant cost for companies, especially smaller ones with limited budgets.
- Misuse: Companies could use fold-out labels to gain greater labelling area for the inclusion of non-mandated information, such as advertising, trade marks, or the addition of languages other than those member states for which the product is intended.
Hazardous chemicals require a label that is durable, secure and permanent, in order to ensure that crucial information remains visible, legible and readily available, even in extreme conditions. The removable adhesives present in the face layer of fold-out labels are designed to be easily removable and can come off when exposed to environmental factors such as heat, moisture, and abrasion. This poses a significant safety hazard as the label may come off, resulting in the loss of critical information and leaving the dangerous chemical unlabelled and potentially leading to accidental exposure to the user and the environment.
Feedback
The EC is currently seeking feedback on the revision of the EU CLP legislation, including the broader use of fold-out labelling, and comments can be submitted until 30th March, 2023.
HOW CAN HIBISCUS HELP
Hibiscus Plc has been providing labelling solutions for the chemical and hazardous goods industries for over 40 years.
Find out how we can improve your hazard communication compliance – Call us today: 0113 242 4272