Using existing information when classifying for CLP

One of the key parts of CLP classification is knowing when to use existing information, and when new information should be generated from tests.

Under CHIP, the precursor to CLP, there was always the legal requirement to use a Harmonised Classification for a substance, and this still applies under CLP (unless there is new information in a REACH dossier which supersedes the Harmonised Classification).

However, there is also published information available nowadays on CLP substance classifications, through the publication of the REACH registration disseminated dossiers, and the Classification and Labelling Inventory on the ECHA website, and these sources should be used before considering testing for substances.

It is also particularly important to ensure that un-necessary animal tests are not carried out, and there is a strong emphasis on the use of  (QSAR) and read-across to related substances to help avoid animal testing.

There are several types of existing information which can be used when classifying for CLP:

• CLP classifications for substances and mixtures
• Non-CLP classifications for substances or mixtures
• Data which supports CLP classification

Classifications for substances can be found in a variety of places, both on the ECHA website and on suppliers’ Safety Data Sheets (SDSs), see https://ttenvironmenta.wpengine.com/knowledgebase_category/published-clp-classifications/ .  Published CLP classifications for mixtures are only usually found in supplier SDSs.

Non-CLP classifications for substances of mixtures are usually only found in supplier SDSs, see https://ttenvironmenta.wpengine.com/knowledgebase_category/published-non-clp-classifications/ .

Published data supporting CLP classification can be found in chemical textbooks, in the REACH disseminated dossiers on the ECHA website, and on supplier SDSs.

Some tips on finding good-quality SDSs

As well as searching for SDSs using the internet, when you can sometimes end up with non-EU SDSs, or SDSs purportedly written to REACH/CLP standards but obviously compiled by people outside the EU with limited knowledge, you can also look at obtaining SDSs direct from distributor or manufacturer websites.

SDSs can often be obtained from reputable company websites, particularly from those based in the EU.  This can sometimes be open-access, such as the Sigma Aldrich (now Merck) website at https://www.sigmaaldrich.com/united-kingdom.html .  Other chemical suppliers may require you to sign up for a free log-in, such as the Tennants Distribution website at http://www.tennantsdistribution.com/ .  However, some companies require you to be a paying customer before they allow you to access their SDSs.

There are also companies who hold libraries of SDSs, and may send you a copy in return for your email address, and these can be useful for products which have been  altered, or which are no longer sold, but are still working their way through the supply chain (this can apply particularly to products which do not have a shelf-life or deteriorate in storage, and are still good quality e.g. 10 years after manufacture).

Whenever you obtain a third-party SDS, you should always treat it with caution:

• has it been compiled by a reputable company?
• does it have data in it, or is it quite “empty”
• does the GHS/CLP classification look reasonable
• if it is outside the EU, or doesn’t have a GHS classification, can the data still be used to generate a CLP classification
• overall, do you trust it? would you be happy to stand up in court and explain why you based your own classification on one in another company’s SDS, or on their data