CLP physical hazard tests
CLP physical hazard tests are identical for both substances and mixtures. These tests are mainly derived from Transport, see Manual of Tests and Criteria Rev 6 2015 .
You should only need to carry out physical tests on substances which are not registered for REACH, or where you are required to derive the CLP classification yourself (e.g. for a novel substance made or imported at less than 1 tonne per annum, or where you are the only REACH registrant).
Physical tests are more likely to be required for mixtures, as these cannot generally be derived by calculation (for the few exceptions to this, see here https://ttenvironmenta.wpengine.com/clp-knowledgebase/physical-hazard-classification-of-mixtures/ ).
Physical hazard tests can be carried out freely, although some of these can be expensive (e.g. explosives testing). There are no restrictions on physical hazard tests as there are with animal tests for health or environmental effects.
Screening for physical hazard tests
The physical hazard tests needed for a substance or mixture are identified on the basis of the chemistry of the product.
To help you with this process, we have produced two screening forms:
(Don’t forget to check that you have correctly identified all the component substances in your mixture, see Checking-for-new-substance-formation-in-a-mixture).
Physical hazard test methods
A list of acceptable test methods is given in CLP and/or Transport for each hazard, and is summarised here for reference: Summary of Physical Hazard Tests for CLP and Transport v1.0 09-05-2017 . This document also includes appropriate REACH methods and OECD test guidelines, where they exist.
Who can carry out CLP physical hazard tests
Physical tests can be carried out by an external test house, or internally, if you have the equipment (e.g. for flash point of flammable liquids, a closed cup flash point apparatus such as Pensky-Martens). Although physical tests must be carried out in conformance with an accepted standard, they are not required to be carried out to GLP standards, or by a toxicology lab. This means that the cost of tests may be cheaper than you might anticipate.
Ideally, any lab carrying out physical tests for CLP classification should be UKAS accredited (if external), or ISO9001 (if in-house), to ensure that there is traceability of the methods used, and a calibration record for instruments used. If you are carrying out physical tests in-house, remember to keep your lab records for 10 years after the date of last supply, as this information forms part of the CLP classification record.
Note that some physical testing, such as explosive testing, is potentially very dangerous and should be carried out at a specialist lab, such as the Health and Safety Laboratory at Buxton, Derbyshire (other explosive labs are available).
Once you have carried out all relevant physical hazard tests, you can classify the substance or mixture from first principles, see https://ttenvironmenta.wpengine.com/knowledgebase_category/first-principles-clp-classification/ .