P Statements

Precautionary Statements, P Statements, are part of GHS, like the pictograms, signal word and H Statements.

Precautionary Statements, as the name suggests, include information on how the handle the product under normal conditions, and what to do in an incident.  There are 5 types of P statement, as follows:

• P100s – only for consumer products
• P200s – prevention
• P300s – response in an incident
• P400s – storage
• P500s – disposal

List of current P statements (GHS-only P statements in italics): List of GHS-CLP P Statements to 8th ATP and Rev 7 GHS v1.2 18-04-2018 .

Amending P Statements

H statements are complete sentences, which are not allowed to be altered in any way, and only a few are allowed to be combined together.

However, P statements are different. As well as there being more combined P statements available than H statements, you can:

• add text, if there is an ellipsis (…..), which indicates that you need to put in appropriate information.  An example is P411, Store at temperatures not exceeding…oC/…oF.  If you don’t put the temperature in, ideally in both Centigrade and Fahrenheit (although you can choose to have only one temperature, see next bullet point), the P statement is meaningless.
• choose one or more options to include in the P statement, if there is one or more forward slash marks. An example is P260, Do not breathe dust/fume/ gas/mist/vapours/spray.  It’s unlikely (if not impossible) that you would have all of these possible air emissions from a single product, so you should choose the most appropriate options for your product. If you were selling a paint stripper containing VOCs, you might warn about vapours; or a dry powder product would include dust, but omit everything else.  A liquid which was sprayed might require mist/vapours/spray to be included in the P statement.
• omit text, where relevant, if there are square brackets round some of a P statement. An example is P303 + P361 + P353, IF ON SKIN (or hair): Take off immediately all contaminated clothing. Rinse skin with water [or shower].  In this case, the text in square brackets should only be included where the manufacturer or supplier considers it appropriate for the specific chemical.

However, like H statements, you should not alter the wording of a P statement apart from the instances described above.

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 .