REACH, CLP, and Safety Data Sheets in the Pulp and Paper Industry: How to Properly Manage Risks of Chemical Raw Materials

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The production of pulp and paper is among the industries with high consumption of chemical raw materials – from hydrogen peroxide and sodium hydroxide to special additives for improving strength or moisture resistance. Each of these substances is subject to strict legislative requirements, particularly the REACH and CLP regulations, which define obligations in the areas of registration, classification, and labelling. Without a proper understanding of Safety Data Sheets (SDS) and related documentation, there is not only a risk of penalties from regulatory authorities but also the danger of endangering workers' health or damaging the environment. How can one navigate this issue, and what should be specifically monitored when selecting raw materials?

REACH and its impact on the paper industry: Registration and obligations

In the paper industry, dozens of chemicals are handled daily – from bleaching agents and coagulants to additives for paper surface treatment. The REACH Regulation (Registration, Evaluation, Authorisation and Restriction of Chemicals) applies to all substances manufactured or imported into the EU in quantities exceeding 1 tonne per year and directly affects how pulp and paper manufacturers manage raw materials. A key obligation is the registration of substances with the European Chemicals Agency (ECHA), which requires detailed data on properties, uses, and risks. Without valid registration, a substance cannot be legally placed on the market, which also applies to many auxiliary chemicals used in paper production, such as retention aids, biocides, or plasticisers.

For paper industry companies, it is crucial to monitor whether suppliers comply with REACH requirements, particularly for substances included on the Candidate List (SVHC – Substances of Very High Concern). These substances are subject to stricter rules, including the obligation to inform customers of their presence in concentrations exceeding 0.1% by weight. Paper manufacturers must also ensure that their own mixtures and preparations do not conflict with REACH restrictions, for example, regarding certain phthalates or perfluorinated compounds. Compliance with these rules is not only a legislative necessity but also a guarantee of safety for employees and the environment.

Classification and Labelling According to CLP/GHS: How to Read Raw Material Labels

The CLP Regulation (Classification, Labelling and Packaging) harmonises the classification, labelling, and packaging of chemical substances and mixtures in the EU according to the globally recognised GHS (Globally Harmonized System). For the paper industry, this means that every raw material – whether sodium hydroxide, hydrogen peroxide, or synthetic polymers – must be correctly labelled with hazard symbols, signal words ("Danger" or "Warning"), and standardised hazard statements (H-phrases) and safety instructions (P-phrases). This information is crucial for the safe handling, storage, and use of chemicals in production.

When purchasing raw materials, it is essential to verify that the supplier complies with CLP requirements, especially for mixtures where classification may be more complex. For instance, some biocides or surfactants may be classified as corrosive, toxic to aquatic organisms, or sensitising. Incorrect labelling can lead to handling errors, increased risk of accidents, or environmental damage. Pulp and paper companies should train employees in interpreting CLP labelling and ensure that all raw materials are stored according to their hazardous properties – for example, separately from flammable substances or in cooled areas if product stability requires it.

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Safety Data Sheets (SDS): How to use them correctly in production

The Safety Data Sheet (SDS) is a fundamental document for managing risks associated with chemical raw materials in the paper industry. It must be supplied with every hazardous substance or mixture and contains 16 mandatory sections that detail physico-chemical properties, health and environmental risks, first aid instructions, measures in case of spills or fire, and disposal information. For paper manufacturers, the SDS is an indispensable tool for planning safe production processes, employee training, and preparing internal regulations.

In practice, the SDS should be accessible to all employees who come into contact with the raw material and regularly updated in accordance with changes in legislation or product composition. For example, for bleaching agents such as sodium hypochlorite, the SDS must include information on reactivity with organic materials or the risk of chlorine release. Paper industry companies should integrate SDS into their occupational safety and health management systems (OSH) and use them as a basis for workplace risk assessments. It is also important to verify that suppliers provide SDS in English and that the data are consistent with the labelling on the packaging in accordance with CLP.

Practical steps for compliance with legislation and risk minimisation

To effectively manage risks associated with chemical raw materials, paper industry companies should implement several key measures. The first step is to establish an internal chemical management system that includes records of all raw materials used, their safety data sheets, and classifications according to CLP. This system should enable quick information retrieval and tracking of updates from suppliers. Furthermore, it is essential to regularly train employees in the safe handling, storage, and disposal of chemicals, with training based on data from SDS and CLP labelling.

Another important element is cooperation with suppliers who comply with legislative requirements. Before purchasing raw materials, it is advisable to verify whether the substances are registered under REACH, whether they have a valid SDS, and whether they are correctly labelled according to CLP. In case of doubt, the ECHA database can be used or experts in chemical safety can be consulted. To minimise environmental risks, it is advisable to prioritise raw materials with a lower environmental impact, such as biodegradable surfactants or chlorine-free bleaching agents. Finally, paper industry companies should regularly audit their processes and documentation to ensure full compliance with legislation and preparedness for potential inspections by regulatory authorities.

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Specific REACH Challenges in the Paper Industry: From Pulp to Final Product

The paper industry processes a wide range of chemical raw materials – from bleaching agents and coagulants in pulp production to additives for paper surface treatment. REACH applies to these substances from the moment of their registration, with the key challenge being the monitoring of the entire supply chain. Pulp manufacturers, for example, must verify whether suppliers of aluminium sulphate or hydrogen peroxide meet registration obligations; otherwise, there is a risk of supply disruptions. It is equally necessary to check whether substances used in paper recycling (e.g., deinking agents) are not included on the list of substances of very high concern (SVHC).

For paper mills, assessing employee exposure during processes such as bleaching, grinding, or drying is also critical. REACH requires manufacturers and processors to conduct risk assessments for all substances in quantities exceeding one tonne per year. This includes measuring workplace air concentrations, analysing skin exposure, and assessing long-term effects. In practice, this means close cooperation with raw material suppliers, who must provide up-to-date safety data sheets and exposure data. Without this information, REACH obligations cannot be fulfilled, and there is a risk of penalties from regulatory authorities.

CLP and Packaging Labelling: How to Avoid Errors When Handling Raw Materials

Classification and labelling according to the CLP Regulation (Classification, Labelling and Packaging) is crucial for the paper industry, as many substances used fall into categories requiring increased caution. For example, sodium hydroxide, used in pulp production, is classified as a corrosive substance (Skin Corr. 1A) and must be labelled with a corrosive hazard symbol along with safe handling instructions. Similarly, substances such as sodium chlorate or certain optical brighteners may be classified as toxic to the aquatic environment (Aquatic Acute 1), which requires appropriate labelling and storage.

Errors in labeling can lead to serious safety incidents, particularly when handling large volumes of raw materials. For example, a mislabeled container of sulfuric acid can cause burns or reactions with other chemicals. Pulp mills should therefore implement a double-check labeling system—first when receiving raw materials from the supplier and again before their use in production. It is also important to train employees so they understand the meaning of pictograms and standardized H (hazard statements) and P (precautionary statements) phrases. Additionally, CLP requires that all labels be in the language of the country where the substance is used, which in the Czech Republic is Czech.

Safety Data Sheets (SDS) as a Risk Management Tool: Practical Tips for Pulp Mills

Safety Data Sheets (SDS) are a key document for the pulp and paper industry, containing information on the physico-chemical properties of raw materials, their toxicity, ecotoxicity, and measures for safe handling. In pulp mills, SDS are often used for employee training, storage planning, or risk assessment. For example, Section 8 (Exposure Controls/Personal Protection) specifies maximum permissible concentrations (OEL) for substances such as formaldehyde or hydrogen sulfide, which may be released during pulp production. These values must be compared with workplace measurement results and protective measures adjusted accordingly.

For effective use of SDS, it is important to have a system in place for their updating and accessibility. Pulp mills should maintain a central database of all raw materials used, where the latest versions of SDS are stored. It is also recommended to regularly check whether suppliers have updated the classification of their products (e.g., due to new scientific findings). In practice, this means establishing a process where, with each raw material delivery, it is verified whether the SDS is still valid. Furthermore, it is advisable to integrate SDS into internal regulations, such as work procedures for handling hazardous substances or emergency plans.

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