Summary of tests for CLP classification

In the absence of data which can be used to make a CLP classification, a series of tests can be conducted on either a substance or a mixture to provide the information needed.  These tests are the same for both substances and mixtures.

There are two types of test:

• physico-chemical tests to provide information on physical hazards
• animal tests to provide information on health and environmental hazards

CLP does not contain many unique tests.  Most physical hazard tests are the same as for Transport, and health hazard and environmental hazard tests are the same as those for REACH or the OECD animal tests.

Physico-chemical tests can be carried out by in-house or external labs as many times as you like (although obviously you will only want to test for hazards that are likely to exist).

Animal tests can only be carried out by suitable labs.  In-vitro tests are preferred, but for many health hazards, few or no in-vitro tests are available for CLP classification, and tests on live animals must be used.  To minimise the number of animal tests carried out, several screening tests are used.  Under UK and EU law, animal tests must be avoided wherever possible.

For substances going through REACH registration, an Inquiry must be made to ECHA before new animal tests can be carried out, and ECHA must approve the tests (approval is not always granted if alternatives exist, or the test is not considered necessary).  Animal tests in the UK may also require HSE approval, whether for REACH or not.

Once test data has been obtained, classification can be carried out from first principles.