Product samples

Samples of a chemical product may be required for a number of purposes, such as customer tests, QC testing, R&D work etc.  Samples are usually sent out to other businesses, rather than consumers, which means that an SDS may be required to be issued automatically, or on request by the recipient.

Samples were traditionally sent out with the product name, and perhaps an SDS if one was available.  However, under CLP, the rules are much more strict:

  • a CLP label must be placed on the sample (note that the CLP classification should already be available, as even an R&D product must be notified to the Classification and Labelling Inventory)
  • an SDS must be provided if required automatically, on or before the first supply; or an SDS must be available on request of the recipient
  • Samples are likely to come under the small packages rules, see https://ttenvironmenta.wpengine.com/clp-knowledgebase/small-packages/ 
  • Sample packages are unlikely to be approved for Transport (although they may be transported in approved outer packages), and instead must meet the CLP packaging rules, see https://ttenvironmenta.wpengine.com/clp-knowledgebase/non-transport-approved-packaging-for-clp-products/
  • Samples do not usually require labelling for Transport because of the Limited Quantities exceptions, although you should always check with your DGSA, as some very hazardous materials may need labelling for Transport
  • Some chemical samples may be unsuitable to send through the post, and some couriers may not wish to carry hazardous goods, so you should check this before sending samples out

The new requirements makes more work for lab staff sending out samples than under CHIP, but the idea is that it makes things safer.

 

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