Summary of the CLP classification process
The CLP classification process involves:
- identifying whether the product is a substance or mixture
- if it’s a substance, checking to see if you can use an existing published CLP classification
- if using a published classification, filling in any gaps, e.g. extra hazards, P statements, EUH statements etc
- if it’s a substance without an existing CLP classification, or a mixture, using existing published non-CLP classifications and converting these to CLP, or using the data in SDSs to classify for CLP
- where there is no existing data, testing a substance to provide data for classification from first principles
- for a mixture with no existing data, obtaining information on the component substances, testing for physical hazards, and using algorithms to classify for health and environmental hazards on the basis of the component substances (including any new substances created by reaction)
Once a CLP classification has been obtained, the classifications are then used to produce full labelling information, which is another series of steps, see https://ttenvironmenta.wpengine.com/clp-knowledgebase/clp-labelling-sequence/ . (Other information, such as EUH Statements is also required for the label).
At every stage of the CLP classification process, records need to be kept to show how you arrive at a particular choice of existing classification, or classification based on data or on algorithms. These records should be kept for 10 years after the date of last supply of the substance (as a minimum).