Information precedence for CLP

Information precedence, that is placing some information on the label and leaving other information off, is applied to labels for four separate pieces of information:

• Signal Word precedence
• Pictogram (symbol) precedence
• H Statement precedence
• P Statement precedence

Precedence of information is worked out when you generate CLP label information, see https://ttenvironmenta.wpengine.com/clp-knowledgebase/generating-clp-label-information/ , in particular on the CLP labelling forms which can be accessed from that page, and also from this page: https://ttenvironmenta.wpengine.com/clp-knowledgebase/labelling-forms/ .

Signal Word precedence

There can only be one Signal Word on any label, and the precedence is:

Danger > Warning > (no signal word)

Under CLP, you cannot put the text “no signal word” on the label, it just has to be absent, but it is possible to place this text in the labelling section of the SDS (Section 2.2).

Pictogram (symbol precedence)

Under CHIP, there was a strict precedence on hazard symbols, so that you could only have a single physical hazard, a single health hazard, and the environmental hazard (if it applied to the product).

With CLP, this situation has changed, and there is a presumption that all symbols generated by the hazard classification will be placed on the label, with the exception of a few situations where one hazard over-rides another.

Note that you only place a pictogram on the label once, if you have three health hazards which all give rise to GHS06, Toxic, the pictogram only appears once.

Pictogram precedence:

• Explosive (GHS01) overrides flammable (GHS02) and/or oxidising (GHS03) unless two symbols apply simultaneously eg H241.
• If flammable (GHS02)or toxic (GHS06) applies to a compressed gas, you don’t need to have the gas bottle symbol (GHS04).
• Corrosive symbol (GHS05) overrides harmful (GHS07) for skin or eye irritation, but not for other risks, eg harmful, skin sensitisation etc.
• Toxic symbol,(GHS06), overrides harmful (GHS07), but not for other risks e.g. skin or eye irritation, skin sensitisation
• If there is a long term health hazard symbol (GHS08) for respiratory sensitisation, do not include harmful (GHS07) for skin sensitisation or skin and eye irritation

Precedence of H Statements

There is very little precedence of H Statements, as most will be placed on the label, and the precedence is:

• Omit H400 if H410 present
• omit H318 if H314 present
• use H410 if H400 and either H411, H412 or H413 applies.

In all cases where precedence of H Statements is used on the label (and placed in section 2.2 of the SDS), the full classification (including H codes) must be placed in section 2.1 of the SDS.

Precedence of P Statements

P Statement preference is often required under CLP, because a maximum of 6 P statements are required on the label, but the hazard classifications of a product can generate many more than 6 P statements, including duplicates, and different levels of precaution for the same type of P statement.

There is very little formal guidance on P Statement precedence, apart from Article 28 of CLP, which states that:

• redundant or unnecessary P statements shall be omitted from the label
• for products sold to consumers, you should put on a P statement for disposal of the substance or mixture, and its packaging, unless not required under Article 22 (which states that the P statements are derived from the classification).  A P statement for disposal is not required if the substance or mixture or the packaging does not present a hazard to human health or the environment

More detailed help on the choice of P statements, including recommendations on which ones are recommended for what situations, is given in ECHA’s guidance on labelling, v3, July 2017: clp_labelling_en v3 2017.

When choosing P Statements, it helps to understand what your end users are doing with the product, and what the package size is, as the P Statements for a bulk flammable material used in industry are likely to be different for a 2.5 litre pot of flammable paint thinners used by consumers.

There is technically no “wrong” choice of P statements under CLP itself, although it is possible that failing to include an important P statement might be considered to be negligent under Duty of Care in the UK.

We have produced a table of P statements by group which may be helpful with choosing the most relevant for your product: P statements by group 18-04-2018.