Scope of CLP Harmonised Classifications

CLP Harmonised Classifications do not cover absolutely everything you need for a substance classification.  Like CHIP, not every hazard end-point is covered, so it is better to consider that Harmonised Classifications are partial (except for biocides or pesticides).  Unlike CHIP, where Safety Phrases were provided and were mandatory, you are required to generate your own P statements.

Harmonised Classifications do not include P Statements

In the Approved Supply List under CHIP, the full information required for each substance (or mixture) was included, such as symbol, indication of danger (e.g. T+ for Very Toxic), Risk Phrases and Safety Phrases.

Under CLP, P Statements (the equivalent of Safety Phrases) are not included, and if you are using a Harmonised Classification you will need to generate them yourself.

Harmonised Classifications may be partial

Harmonised Classifications do not always cover every single possible hazard from a substance, and it can be better to consider them to be “Harmonised Partial Classifications”.  Only biocides and plant protection products are required to include every single hazard in their Harmonised Classification.

Where a Harmonised Classification is partial, the person classifying the substance should add in any classifications required for non-harmonised hazards, to ensure a substance is classified fully.

This situation also occurred for CHIP classifications in the Approved Supply List, as some classification hazards such as corrosive to metal were omitted.

One place to get this extra information from is the REACH dossiers, as REACH registrants are required to consider every single CLP hazard as part of the registration process.  If the REACH dossier is reliable, or you think that the specific test data or read-across data is reliable, then you may want to use the REACH classification for a specific substance (although be aware that you should not breach copyright rules).

For information on obtaining CLP classifications from REACH dossiers, see this article: https://ttenvironmenta.wpengine.com/clp-knowledgebase/reach-dossiers/.

In the absence of a REACH dossier, there may be relevant information in the Classification and Labelling Inventory, see https://echa.europa.eu/information-on-chemicals/cl-inventory-database .

What hazards will be included in a new Harmonised Classification under CLP

Going forward under  CLP, the hazards which are required to be included in a Harmonised Classification (except for biocides and plant protection products), are:

• respiratory sensitisation, category 1, 1A or 1B, (H334)
• germ cell mutagenicity, category 1A, 1B (H340) or category 2 (H341)
• carcinogenicity, category 1A, 1B (H350) or category 2 (H351)
• reproductive toxicity, category 1A, 1B (H360) or category 2 (H361)

Note that this list covers fewer hazards than under the Approved Supply List, although existing Harmonised Classifications will not have harmonised hazards removed retrospectively.

This means that information in the REACH dossiers and C&L Inventory will become more important in filling the gaps in the new Harmonised Classifications.