CLP-GHS classifications

Definition of CLP classification

There is no formal definition of what a GHS classification actually is, and this lack of definition appears to have been adopted within CLP as well.

This is rather unsatisfactory because it does not make legally clear what is being discussed, or what is required of someone classifying, labelling and writing SDSs.

The UK REACH and CLP Helpdesk was approached for their opinion, and they suggest that the CLP classification should comprise three elements:

• the hazard class (e.g. flammable liquid)
• the hazard category (e.g. category 2)
• the H code (e.g. H225)

The reasons for this are understood to be (a) because this is the definition used in the Harmonised Classifications within CLP, although not explicitly described in the legal text; and (b) because using the hazard class and category without the H code, or the H code without the other information, may not fully describe the hazards, as there is not a 1:1 relationship between hazard class and H code.

Differences between H code and rest of hazard classification

Although the HSE definition is pragmatic, there are some discrepancies between the H code and the rest of the hazard classification (the hazard class and category).

• Not every Hazard Class has a Category Code – Pressurised Gas does not have a Category Code.
• Not every Hazard Class and Category Code has a Hazard Statement Code and Hazard Statement. Pressurised Gas does not have a Hazard Statement Code and/or Hazard Statement.  Neither does Explosive division 1.6.
• There is not a 1:1 relationship between the two component parts of a classification, that is “Hazard Class and Category Code” and “Hazard Statement Code”, e.g. flammable solids cat 1 and cat 2 both have H code H228.

There is a list of the differences here: Differences between H codes v1.1 20-06-2017.

Note that only the Hazard Statement text appears on the label, so for the classifications where there is a discrepancy between the H statement and classification, you may need to read the SDS to fully understand what the classification is as a whole.

Use of abbreviations in CLP-GHS classifications

CLP tends to use abbreviated forms of the hazard class and hazard code, e.g. Explosives division 1.1 becomes Expl. div. 1.1; and Skin Corrosion / irritation category 2 becomes Skin Irrit. 2.

List of current CLP-GHS classifications

A full list of all of the current CLP-GHS classifications is given here: List of CLP-GHS classifications to 8th ATP & GHS Rev 7 .  The hazard classes are divided into Physical, Health and Environmental hazards.

Not all GHS classifications have been brought into CLP at the time of writing this article, and GHS-only classifications are shown in italics.

Some may be brought in at a later date (when GHS revision 6 is adopted), and others are unlikely ever to be adopted by the EU.  This poster (A3) shows the relationship between the two systems: GHS classifications and whether adopted into CLP v2.3 .

Why the CLP-GHS classification is so important

The CLP-GHS classification defines all of the other GHS labelling information, that is:

• pictogram(s) (or symbols(s)), where one or more applies to the classification
• signal word, if one applies to the classification
• H statement text
• P statement text

This information has been summarised into a series of look-up tables at GHS-CLP Classification Summary Sheets v2.4, and more information on this process is given at https://ttenvironmenta.wpengine.com/clp-knowledgebase/generating-clp-label-information/ .

EUH statements are not part of the CLP-GHS classification

EUH statements are derived separately, see https://ttenvironmenta.wpengine.com/clp-knowledgebase/euh-statements/ .  They are considered to be labelling information, and as such as not technically part of the classification per se (although having a legal definition of the CLP classification would help clarify their status!).

Use of short codes to describe CLP-GHS classifications

In the fragrance and flavouring industry, a series of unambiguous short codes have been developed to identify CLP-GHS classifications, without the inherent ambiguity which occurs in the legal text.  These short codes omit many physical hazards, as fragrances and flavourings tend not to have many physical hazards, and certainly not the more severe classes (e.g. explosive).

These short codes take the form of text to describe the hazard class uniquely, and a number for the hazard category. Examples include ED2 (ED = eye damage, so ED2 = eye irritant 2); or ATO4 (acute toxicity oral 4, H302).

A list of the IRFA short codes is provided here:Short-codes-for-GHS-classifications  and a translation table from the short codes to CLP-GHS equivalents is given here: Table with IFRA and IOFI short codes and CLP equivalents .

Use of hazard class numbers within CLP regulation text

To make the situation even more complicated, CLP occasionally refers to hazard classes by their chapter number, as a shorthand.  You should not use hazard class numbers for classifying, but it can be useful to know what they stand for when reading the various derogations and cross-references within the CLP regulation.  A list of the Hazard Classes by number is provided here for reference: Hazard classes within CLP .