Converting CHIP classifications to CLP
There are two ways to classify a substance or mixture for CLP using CHIP information:
- classify on the basis of data available in a CHIP Safety Data Sheet (SDS)
- convert the CHIP classification into a CLP classification using the Annex VII method
The first method involves classifying from first principles on the basis of data, using these methods, see https://ttenvironmenta.wpengine.com/clp-knowledgebase/using-data-from-non-clp-safety-data-sheets/ and https://ttenvironmenta.wpengine.com/knowledgebase_category/first-principles-clp-classification/ .
The second method involves reading across from the tables given in Annex VII to CLP, also called the “Annex VII reclassification method”. It can be used for the reclassification of either substances or mixtures.
However, using the Annex VII reclassification method may give rise to over-classification, particularly for mixtures, and we recommend that if you have information on the CHIP classification of component substances, it can be more accurate to reclassify the substances according to the Annex VII method (or use published classifications for these), and then classify the mixture using the CLP algorithms method.
Annex VII works because some of the thresholds for hazards are identical for CHIP and CLP, and are therefore directly equivalent; and other thresholds are similar or can be used as “worst-case” classifications.
Not every hazard can be translated like this, but it can be used for most hazards, especially in conjunction with Transport hazard information (eg explosives can’t be classified using the Annex VII method from CHIP to CLP, but are classified the same under CLP as for Transport).
Some physical hazards (e.g. flammability) may require test data, (for flammability, flash point and boiling point information), especially if Transport information is not available.
The Annex VII method is not as accurate as translating from CHIP to CLP on the basis of test data, but it is generally quicker.
The Annex VII form can be downloaded here: Form for Annex VII CHIP to CLP v1.1 29-06-2017 . To use the form, print off a hard copy and highlight the CHIP classifications and read across to their CLP equivalents (where these exist). The completed form should be retained as part of your classification records.