Moving Towards A World-Wide System For Communicating Chemical Hazards In The Workplace.As a global market leader in the metalworking fluids business, Houghton

International, Inc. has proactively taken steps to ensure timely compliance with

the U.N. Standard for the Globally Harmonized System (GHS) for Classification and

Labelling of Chemicals. This includes compliance with the European Classification,

Labelling and Packaging (CLP) legislation. The information provided within this

brochure is for reference purposes only and reflects Houghton’s understanding and

the actions underway to address GHS-related regulations for Europe. We actively

encourage our customers and distributors to consult with their own regulatory

advisors and legal counsel regarding any specific actions they may need to take.

During the transition phase, our sales professionals and regional experts in

product safety and regulatory affairs are available to answer your questions

regarding our products and compliance with GHS. Please email:

ProductStewardship@houghtonintl.com

What Is GHS?The primary purpose of the Globally Harmonized System (GHS) is to standardize

the classification and labelling of hazardous chemicals to aid in the communication

of critical chemical safety and handling information including the use of

internationally recognized pictograms on Safety Data Sheets (SDS) and container

labels. GHS is an international mandate developed by the United Nations in 1992

with the intent that individual countries around the world adopt the standard

as a part of their regulatory process for managing hazardous chemicals. GHS is

structured to improve worker understanding of hazards in the workplace and to

reduce barriers to international trade.

RESPONSIBLE PRODUCT STEWARDSHIP

GHS World-WideGHS is neither a global law nor

regulation. It is a system or a set

of recommendations that utilize

a “building block” approach. No

country is obligated to adopt all

or even any part of GHS elements.

Countries are free to determine

which of the building blocks they

will adopt but the portions of GHS

that are adopted must follow the

GHS standard.

June 1, 2015 Timeline:

• Europe

• United States

• Canada—pending

• Mexico—not mandatory

• Brazil

• Singapore

Several countries have already

implemented GHS while others

have later deadlines or have not yet

adopted GHS.

Houghton International Product Stewardship Preparing for GHS in Europe

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The Globally Harmonized Systemof Classification and Labelling of Chemicals

GHS |

CLP vs. GHSThe CLP legislation has adopted portions of GHS. CLP incorporates the GHS criteria

and provides a new method for classifying chemicals based on their health and

physical hazards. Not all regions have adopted all criteria, including Europe.

For example, CLP has not adopted all of the criteria for combustible liquids.

Manufacturers are still required to classify chemicals (using newly adopted GHS

criteria), provide these SDS to customers and provide proper product labels.

Employers are still required to have a hazard communications plan, conduct

employee training, maintain copies of SDS for chemicals used in the workplace and

properly label all hazardous chemicals.

What Are The Key CLP Deadlines?Under CLP, all employers were required to initiate training for their employees

on the new label elements and SDS format no later than December 1, 2010.

Manufacturers, distributors and importers were required to reclassify and/or

provide updated SDS and product labels for all substances in the GHS format as

of December 1, 2010. Updated SDS and labels in GHS format will be required for

mixtures from June 1, 2015. There is a transition period for existing stock of 2 years

up to June 1, 2017. Finally, employers are required to be fully compliant with GHS for

inventoried products including updating alternative workplace labelling and hazard

communications plans. Employers must also provide additional employee training

for newly identified health and physical hazards identified on the SDS.

Who Is Affected?If you manufacture, import, distribute, transport or use hazardous chemicals,

you will be affected. GHS covers all hazardous chemicals without exception. The

term “chemical” is used broadly to include substances, products, mixtures and

preparations. All chemical manufacturers, importers and distributors who are subject

to CLP will need to adapt to the new GHS-based rules.

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CLP Implementation Timeline

Houghton International will be

providing GHS-compliant SDS and

product hazard labels using CLP. As

always, our SDS and labels will be

provided in a range of languages

depending on the location shipped.

By June 1, 2015, GHS-compliant SDS

and product labels will be in use for

all active products sold by Houghton

International in Europe.

2010

Initiate GHS training for all employees

Manufacturers and distributors reclassify and update labels and SDS for substances in GHS format

Manufacturers and distributors reclassify and update labels and SDS for mixtures in GHS format

Compliant GHS format SDS and labels for all existing stock in the supply chain

2010December 1

2017June 1

2015June 1

How Will Product Hazard Labels Change?The information on the labels will become standardized to increase employee comprehension of the potential hazards and

precautions related to the chemical product in each package or container. The standardized label elements include:

What Hazards Do The New Pictograms Represent?

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Hazard symbols called PICTOGRAMS (shown above) represent health, physical and environmental hazard

information. There are nine pictograms that are assigned to 28 different GHS hazard classes and categories.

The 5 pictograms outlined in yellow are those most commonly used for metalworking fluids.

1.

HAZARD STATEMENTS: Standard phrases assigned to each hazard class and category that describe

the nature of the hazard. 3.

SIGNAL WORDS “Danger” or “Warning” are used to emphasize the relative level of severity of

the hazard assigned to each GHS hazard class and category.2.

PRECAUTIONARY STATEMENTS: Describes the recommended measures to minimize or prevent

adverse effects resulting from exposure including prevention, response, storage and disposal.4.

5. It is still required that the product name (same as SDS), the name, phone number and address of the

manufacturer, distributor or importer (responsible party) are included on the container label.

Will Workplace Labelling Change?Products falling within the scope of GHS will have GHS

labels at the point where they enter the workplace.

The GHS label or label elements can also be used for

workplace containers. However, employers can also

choose to communicate information using alternative

methods where chemicals are transferred from supplier

containers to containers for laboratory testing, storage

vessels, piping or process reaction systems; or temporary

containers where the chemicals will be used within a

short time frame.

Where national workplace legislation covering labels

exists, alterative workplace labels should be in compliance

with those requirements.

How Will Safety Data Sheets Change?CLP SDS follow a standardized 16-section format similar

to previous legislation. The SDS will continue to provide

hazard and precautionary information about a chemical

substance or mixture. The primary purpose of the SDS

is to provide employers/employees with information

to support the evaluation of workplace hazards and

appropriate safety precautions. Under GHS, the SDS will

specify the hazard class and category for the substance

or mixture. For each hazard class and category, the SDS

will identify prescribed/mandated hazard statements,

pictograms and precautionary statements.

Our ApproachHoughton International Inc. is a global market leader in

metalworking fluids and related value added technical

services. Metalworking fluids (MWF) are mission-

critical specialty chemicals used for metal removal, heat

treatment and quenching, rust prevention, specialty

hydraulics, rolling oils and related applications.

Houghton employs a wide range of chemicals and

additives in the manufacture of our metalworking fluid

formulations. This allows us to offer a broad product

line with many options to meet customer specific as

well as region/country specific EHS and/or regulatory

requirements. We have many product options that are

non-hazardous and/or do not contain raw materials that

may have mixed acceptance in certain regions/ countries.

Houghton routinely reviews these materials as new

information and data is made available.

As part of our product stewardship commitment, we

continue to make EHS a priority in our planning for new

and existing products and actively counsel customers on

the safe use, handling, transport and disposal of

our products.

4

Explosive (E)

Extremely (F+) and Highly Flammable (F)

Oxidizing (O)

Very Toxic (T+) and Toxic (T)

Harmful (Xn) or Irritant (Xi)

Dangerous for environment (N)

Old Pictograms (DSD/DPD)

New Pictograms (GHS/CLP)

Corrosive (C) To eyes or skin

Will ADR Transport Pictograms Change?For transport, existing transport pictograms will be used and will maintain the background and symbol colours currently used.

Where a transport pictogram appears, the GHS pictogram for the same hazard should not appear.

It is important to note that changes in hazard classification under GHS may impact the classification under other related

regulations (e.g., corrosive under GHS = corrosive under Dangerous Goods/ADR).

5

Our Commitment

“Here at Houghton, we are committed to meeting

all environmental, health and safety and product

regulatory requirements in the markets we serve

including GHS. Our broad and deep product portfolio

provides many options that allow us to meet

application/performance, regulatory, EHS and other

requirements for our customers world-wide”

Ria Scheuren

Vice President, EHS & PSOPEN

COMMUNICATION INNOVATIVE

RECEPTIVE TO CHANGE

RESULTS DRIVEN

EHS FOCUS

CUSTOMER FOCUS

GLOBAL TEAM

PLAYERINTEGRITY

6

Will GHS Have Any Impact On The Chemical Composition Of Houghton Products?Houghton is not changing product formulations as a result of GHS. Under GHS,

the classification system has changed, resulting in different, often lower thresholds

and hazard criteria. Suppliers of raw materials are also providing updated and

detailed information as a part of their preparation for GHS. It is possible that the

classification of some products may change. Houghton has no plans at this time to

discontinue use of any of its raw materials or products as a result of GHS. Houghton

does routinely evaluate its raw materials and product formulations and may modify

or discontinue products when versions with better performance, quality, cost,

consistency and EHS can be achieved.

What Can You Expect From Houghton?Houghton is committed to helping our customers and distributors understand GHS.

We have followed the GHS rulemaking since it started and our product safety and

regulatory affairs experts have been involved with organizations to help shape GHS

implementation.

We will support our customers and distributors by:

• Properly classifying our products

• Making sure our product SDS, labels and marketing materials meet GHS requirements

• Training our sales and technical service representatives so they can help you

understand GHS and answer your questions

• Direct access to SDS via a customer web portal by June 2015

HI 10027 14.10 GB

How Can I Learn More About Houghton’s European Implementation?If you have any questions about

Houghton’s GHS implementation in

Europe, please contact your local

Technical Sales Representative or

our Product Stewardship Team

(ProductStewardship@houghtonintl.com).

You can also visit our website at

www.houghtonintl.com/ghs

Where Can I Get More Information About GHS And CLP?To learn more about GHS and

CLP, please visit:

• United Nations: http://www.unece.

org/trans/danger/publi/ghs

• ECHA: http://echa.europa.eu/

Contact UsHoughton PLC

Beacon Road, Trafford Park

Manchester MI7 IAF

United Kingdom

Tel: +44 (0) 161 874 5000

Fax: +44 (0) 161 874 5001

Email: uk.enquiries@houghtoneurope.com

productstewardship@houghtonintl.com(for specific GHS inquiries)