Generated by All in One SEO v5.0.1.1, this is an llms.txt file, used by LLMs to index the site. # TT Environmental Consultancy Yorkshire ## Sitemaps - [XML Sitemap](https://ttenvironmental.co.uk/sitemap.xml): Contains all public & indexable URLs for this website. ## Posts - [News](https://ttenvironmental.co.uk/news/) - [Intensive CLP Training Courses, 19th and 20th June and 27th and 28th June 2018](https://ttenvironmental.co.uk/intensive-clp-training-courses-19th-and-20th-june-and-27th-and-28th-june-2018/) - TT Environmental will be running our 2-day Intensive CLP Training Course or the last time in its current format on 19th and 20th June, and again on 27th and 28th June. After June 2018, we are looking to move the course online, and we will be less likely to offer live training. The course includes - [Intensive CLP Training Course 9th and 10th January 2017](https://ttenvironmental.co.uk/intensive-clp-training-course-9th-and-10th-january-2017/) - We are running our popular Intensive CLP Training Course again on 9th and 10th January 2018 at the Cedar Court Hotel, Huddersfield (just off Junction 24 of the M62) https://www.cedarcourthotels.co.uk/hotels/huddersfield-halifax. “Many thanks for a fantastic course. I learnt a lot and it will help immensely with our products and procedures”. (IL, 2015) Details: 2 day intensive CLP - [CLP Training 29th and 30th November 2017](https://ttenvironmental.co.uk/clp-training-29th-and-30th-november-2017/) - We are running our Intensive CLP Training Course again on 29th and 30th November 2017 at the Cedar Court Hotel, Huddersfield (just off Junction 24 of the M62) https://www.cedarcourthotels.co.uk/hotels/huddersfield-halifax. Details: 2 day intensive CLP course from TT Environmental Ltd v1.2 26-06-2017 If you would like more information, or to book on this course, email info@ttenvironmenta.wpengine.com . - [Is your CLP classification software helping you?](https://ttenvironmental.co.uk/is-your-clp-classification-software-helping-you/) - When you buy and use a piece of software to help with a problem, most of the time it's a big improvement on trying to do things by yourself, and CLP classification and Safety Data Sheet software packages are no exception. However, some software packages appear to have a glitch which can lead to under-classification - [Grenfell Enquiry - Hackitt to chair Building Regs Enquiry](https://ttenvironmental.co.uk/grenfell-enquiry-hackitt-to-chair-building-regs-enquiry/) - At last, some positive news surrounding the investigations into the Grenfell Tower disaster - Dame Judith Hackitt, former chair of the HSE, is to chair an enquiry into the Building Regulations, for details see http://www.constructionenquirer.com/2017/07/28/building-regulations-to-be-reviewed-in-wake-of-grenfell/ . The devastating fire at Grenfell Tower has many hallmarks of a Major Accident in the chemical industry, and it is - [Keeping out of REACH legally for small quantity imports](https://ttenvironmental.co.uk/keeping-out-of-reach-legally-for-small-quantity-imports/) - If you are importing a substance at just above the 1 tonne per annum limit, you may be thinking about whether to register for REACH in 2018, or whether you should reduce your import quantity to avoid REACH. The first scenario can be very expensive on a cost per kilo basis; and the second scenario could - [Newsletter #26, more on 8th ATP to CLP, and the 9th ATP to CLP](https://ttenvironmental.co.uk/newsletter-26-more-on-8th-atp-to-clp-and-the-9th-atp-to-clp/) - 12th October 2016 Dear reader, It’s becoming traditional for the EU to issue a flurry of regulations in June and July before the Continent shuts down for most of August, and 2016 followed this pattern. I had just managed to send out our previous newsletter, which included some information on the 8th ATP to CLP, - [Intensive CLP Training Course, 3rd and 4th November 2016](https://ttenvironmental.co.uk/intensive-clp-training-course-3rd-and-4th-november-2016/) - We are running our 2-day Intensive CLP Training Course on 3rd and 4th November 2016, at the Delvers Inn, Wainstalls, HX2 7TE. Course details here: 2-day-intensive-clp-course-from-tt-environmental-ltd . Only 2 spaces left! For more information, or to book, contact Janet on janet@ttenvironmental.co.uk or call 01422 242222. - [List of substances with changed Harmonised Classifications made in 9th ATP to CLP](https://ttenvironmental.co.uk/list-of-substances-with-changed-harmonised-classifications-made-in-9th-atp-to-clp/) - The 9th ATP to CLP changed the Harmonised Classifications of 50 substances: Substances where the Harmonised Classification has been deleted (2) Substances whose Harmonised Classification has been changed (22) Substances with a new Harmonised Classification (26) Download a factsheet containing these three lists, including CAS number and EC number here: List of substances with changed Harmonised Classifications made in - [Newsletter 25 - COMAH and REACH news, 8th ATP to CLP, and Brexit.](https://ttenvironmental.co.uk/newsletter-25-comah-and-reach-news-8th-atp-to-clp-and-brexit/) - 15th July 2016 Dear reader, Please note that this email was written on 14th July 2016, but delivery was delayed until Monday 18th July 2016, as we all came to terms with the news of the terrorist atrocity in Nice. COMAH COMAH change to calculations based on CLP rather than CHIP The deadline for re-notifying - [Newsletter 24 - COMAH deadline, IUCLID6 release, Waste documentation changes etc](https://ttenvironmental.co.uk/newsletter-24-comah-deadline-iuclid6-release-waste-documentation-changes-etc/) - TTE Newsletter 24–COMAH deadline, IUCLID6 release, Waste documentation changes etc Welcome to the first of the new format TT Environmental newsletters, which you are receiving because you’ve signed up from our website; are a subscriber to our old newsletter; or are a client or contact of ours. I hope you find it useful, but if - [ECHA newsletter with SME interview](https://ttenvironmental.co.uk/echa-newsletter-with-sme-interview/) - The May 2016 ECHA newsletter contains an interview about things SMEs need to consider in the run up to 2018, given by Janet Greenwood on behalf of the Chemical Regulations Self Help Group, www.chemselfhelp.co.uk . The article is available online at http://newsletter.echa.europa.eu/home/-/newsletter/entry/2_16_reach-2018-things-for-smes-to-think-about, and a pdf of the newsletter can be downloaded here http://newsletter.echa.europa.eu/documents/6362380/22230354/newsletter_2016_issue_2_may_en.pdf . - [Buncefield Prosecutions](https://ttenvironmental.co.uk/buncefield-prosecutions/) - Buncefield prosecutions, and what it means for your business You might think that the Buncefield prosecutions are irrelevant because your site isn't in COMAH, but the new Environmental Damage Regulations due to come into force in 2009, (see draft regulations and guidance) will make businesses of any type liable for cleaning up environmental damage whether - [ECHA Stakeholder Meeting 24th - 25th May 2016](https://ttenvironmental.co.uk/echa-stakeholder-meeting-24th-25th-may-2016/) - Janet Greenwood of TT Environmental Ltd will be speaking at this meeting on 25th May 2016, on behalf of the Chemical Regulations Self Help Group www.chemselfhelp.co.uk, about SME experiences of REACH registration. For details, see http://echa.europa.eu/news-and-events/events/event-details/-/journal_content/56_INSTANCE_DR2i/title/11th-stakeholders-day . - [ECHA intends to stabilise REACH guidance 2016 - 2018](https://ttenvironmental.co.uk/echa-intends-to-stabilise-reach-guidance-2016-2018/) - ECHA intends to "stabilise" its REACH guidance (that is, not change it) from 31st May 2016 to the final registration deadline in 2018, see http://echa.europa.eu/view-article/-/journal_content/title/echa-stabilises-guidance-two-years-ahead-of-the-2018-reach-deadline . - [Article on Poison Centre requirements](https://ttenvironmental.co.uk/article-on-poison-centre-requirements/) - Great summary article on new Poison Centre requirements at Speciality Chemicals Mag see http://www.specchemonline.com/articles/view/beware-poison - [ECHA Infocard Classifications May be Misleading](https://ttenvironmental.co.uk/echa-infocard-classifications-may-be-misleading/) - You may have noticed that the chemical search function at ECHA changed recently, and that there are now different levels of information available. The first level (and therefore first result in a chemical search) is called an "Infocard", which summarises basic information about the substance, including CLP classification information. The CLP classification information is generated - [REACH Pre-registration Workshop](https://ttenvironmental.co.uk/reach-pre-registration-workshop/) - If you think your business might be REACH-liable, are unsure about what you should pre-register, or why you should pre-register, our REACH self-help group’s workshop on Getting Ready for REACH Pre-Registration may be able to help you. Pre-registration is the key to REACH – if you, or your suppliers, don’t have chemicals or REACH-liable substances - [EP Important Information for Low Impact sites](https://ttenvironmental.co.uk/ep-important-information-for-low-impact-sites/) - One of TT Environmental Ltd’s clients just missed the deadline for submitting their Low Impact Application under the PPC regulations at the end of March, and it is being processed as one of the first to go through the new Environmental Permitting regime. Unlike our previous Low Impact clients under PPC, they have been told - [Introduction to CLP, April 2009](https://ttenvironmental.co.uk/introduction-to-clp-april-2009/) - CLP is the Classification, Labelling and Packaging Regulation, EC No 1272/2008. It’s the EU’s way of implementing GHS, the Globally Harmonised System for hazardous substance classification. This will run alongside, and eventually replace, the current system for classifying substances for supply, which is the CHIP regulations in the UK. Main changes from current CHIP3 There - [Who should notify what substances under CLP](https://ttenvironmental.co.uk/who-should-notify-what-substances-under-clp/) - CLP Notification is now required under EU law for any substance placed on the market in any amount. Unlike REACH there is no 1 tonne cut-off point. We understand that this also applies to R&D materials, inter-company transfers e.g. from outside the EU into the EU, etc. There is a phase-in period for substances which - [Biodiesel Health & Safety](https://ttenvironmental.co.uk/biodiesel-health-safety/) - Health and Safety Executive information on Biodiesel Health & Safety At the recent Hazards XX conference in Manchester, the HSE presented a paper on the dangers of biodiesel manufacture. They are concerned about the risks from biodiesel esterification process, mainly from the use of caustics (NaOH, KOH), and from methanol (including inhalation and ingestion risks, - [LEV guidance from HSE](https://ttenvironmental.co.uk/lev-guidance-from-hse/) - One of HSE's current "hot topics" is Local Exhaust Ventilation (LEV). This seems to coincide with the publication of new LEV guidance, HSG 258, Controlling airborne contaminants at work, a guide to local exhaust ventilation (LEV). One of our clients in Birmingham has already been picked up on the need for an LEV to control - [Environmental Permit HAZOP requirements](https://ttenvironmental.co.uk/environmental-permit-hazop-requirements/) - There is a new “plain English” guidance on “getting the basics right: how to comply with your Environmental Permit”, which is free to download from the Environment Agency website at http://www.environment-agency.gov.uk/commondata/acrobat/basics_2002267.pdf. This interesting document includes a statement on p9 "for the larger or more complex activities in Schedule 1 of the Environmental Permitting Regulations you - [Containment Improvements after Buncefield](https://ttenvironmental.co.uk/containment-improvements-after-buncefield/) - The spectacular fire at Buncefield on 11th December 2005 was extremely fortunate in that there were no fatalities, but it did result in significant loss of containment during the fire, allowing firewater to affect local land and groundwater. Buncefield has been considered to have had a large enough adverse impact on the environment to require - [EA Poultry Prosecution](https://ttenvironmental.co.uk/ea-poultry-prosecution/) - In the courts - company fined for not having Environmental Permit We have been helping a Bradford Poultry Slaughterhouse submit a late Environmental Permit application, after they had a scary visit from the Environment Agency pointing out that they required one. Food sites are different from chemical factories, because there is a 50 tonne per - [CLP and Classification for Transport Changes](https://ttenvironmental.co.uk/clp-and-classification-for-transport-changes/) - Gill Pagliuca, Denehurst Chemical Safety Ltd, www.denehurst.co.uk. GHS (the Globally Harmonised System of Classification and Labelling of Chemicals) is not only the basis for the EU's new CLP regulation, covering the classification and labelling of chemicals for supply purposes, but it also underpins the classification of chemicals for transport. This is illustrated in Figure 1 - [CHIP 2008 COMAH](https://ttenvironmental.co.uk/chip-2008-comah/) - New CHIP regulations 2008 and their impact on COMAH and Environmental Permits. The latest CHIP amendment came into force on 1st October 2008, www.hse.gov.uk/chip/issues. There are a variety of changes, including a change in the rules for classifying and labelling preparations containing carcinogens, mutagens and toxic for reproduction substances; and also a change in the - [REACH Costs Nightmare](https://ttenvironmental.co.uk/reach-costs-nightmare/) - REACH Costs - how a micro-SME nearly came to grief. One of our Self Help group members has had a very near miss over REACH data costs. The substances is a CMR (Carcinogen/ Mutagen/ Reprotoxin), used only as an industrial intermediate, so it has a 2010 registration deadline. In late 2009, the member received what - [Improved chemical search at ECHA](https://ttenvironmental.co.uk/improved-chemical-search-at-echa/) - ECHA have improved their chemical search function to give substance identity, including structure, on results page, ahead of links to CLI, registered substance information, see http://echa.europa.eu/ . - [REACH cost share regulation published](https://ttenvironmental.co.uk/reach-cost-share-regulation-published/) - New regulation clarifies cost sharing for REACH data, see http://echa.europa.eu/view-article/-/journal_content/title/reach-data-sharing-principles-clarified . - [Beware potentially fake Lead Registrants](https://ttenvironmental.co.uk/beware-potentially-fake-lead-registrants/) - Several companies we know have been receiving emails from more than one company claiming to be the Lead Registrant for the same substance. This has occurred where there is no Lead Registrant officially in place, or even where a Lead Registrant exists, and the substance has been registered. ECHA has published guidance on how to ## Pages - [TT Environmental Ltd](https://ttenvironmental.co.uk/) - [Login](https://ttenvironmental.co.uk/login/) - [Account](https://ttenvironmental.co.uk/account/) - [Thank You](https://ttenvironmental.co.uk/thank-you-2/) - Your subscription has been set up successfully. - [Sevaluate™](https://ttenvironmental.co.uk/comah/sevaluate/) - SevaluateTM is an Excel based program which runs your COMAH (Seveso III) calculations for you, provides printable reports showing the main contributors to your COMAH liability, and allows you to predict the impact of changing your COMAH inventory on your COMAH liability. It’s ideal for demonstrating your COMAH status to the HSE, particularly for sites - [Contact Us](https://ttenvironmental.co.uk/contact-us/) - If you need more information today, please call: 01422 24 22 22. TT Environmental Ltd Heights Lodge North Wainstalls Halifax HX2 7TR T: 01422 24 22 22 Email janet@ttenvironmental.co.uk - [Quick Consultancy Calls](https://ttenvironmental.co.uk/quick-consultancy-calls/) - If you have a specific chemical regulations problem which needs sorting out quickly, we can help you on a confidential pre-paid Zoom meeting, and you’ll get a copy of the call afterwards as a record. (This replaces the Support Contracts we used to offer). We have two meeting types, and you can choose to book - [CLP Training](https://ttenvironmental.co.uk/clp/clp-training/) - Our main training course, CLP Mastery, is available from www.ghsclassificationcourses.com . The Accountability Programme version is a hybrid online/ live video meet-up training course, combining the best of virtual and personal training, where we take a small group through the course in 10 to 12 weekly meetings (and you have access to everything for a - [Environmental Permit / IPPC Overview](https://ttenvironmental.co.uk/ippc-environmental-permit/) - The Environmental Permitting (EP) Regulations came into effect on 6th April 2008 throughout the UK; since then they have been updated by the Environmental Permit 2010 Regulations (as amended in 2013, 2014 and 2015). This replaced the Pollution Prevention Regulations, which have been in force since 2000 as the IPPC regime. In Scotland and Ireland, - [About us](https://ttenvironmental.co.uk/about-us/) - TT Environmental Ltd is a specialist chemical and environmental consultancy helping industry and business meet their environmental and chemical safety obligations. We can help you: Please note that in order to comply with the requirements of the Provision of Services Regulation 2009, we provide services to businesses and not directly to private individuals. As a - [Meet The Team](https://ttenvironmental.co.uk/about-us/the-team/) - Janet Greenwood, BSc, MSc, FISoilSci. Managing Director and Soil Scientist.Chartered soil scientist with chemical industry experience in speciality chemicals, founder and owner of successful environmental consultancy business serving chemical industry and chemical-using manufacturing industry. - [CLP-GHS Knowledgebase](https://ttenvironmental.co.uk/clp/clp-ghs-knowledgebase/) - The CLP Knowledgebase has been migrated to a new website at www.ghsclassificationcourses.com . For access, or more information, please contact janet@ttenvironmental.co.uk . - [Account](https://ttenvironmental.co.uk/tt-environmental-ltd/account/) - [wpcw_account] - [Statutory Information](https://ttenvironmental.co.uk/about-us/statutory-information/) - Company Information TT Environmental Ltd, Registered in England & Wales no 4273163. Established 2001. Registered office: North Heights Lodge, Wainstalls. HX2 7TR. VAT Reg no: 772 8308 09 Telephone: 01422 24 22 22 Email: info@ttenvironmenta.wpengine.com Provision of Services Regulation, 2009 TT Environmental Ltd provide environmental, chemical and business consultancy services to businesses. We do not - [Website Acceptable Use Policy](https://ttenvironmental.co.uk/about-us/website-acceptable-use-policy/) - This acceptable use policy sets out the terms between you and us under which you may access our website www.ttenvironmental.co.uk (our site). This acceptable use policy applies to all users of, and visitors to, our site. Your use of our site means that you accept, and agree to abide by, all the policies in this - [Website Terms of Use](https://ttenvironmental.co.uk/about-us/website-terms-of-use/) - PLEASE READ THESE TERMS AND CONDITIONS CAREFULLY BEFORE USING THIS SITE Terms of website use This terms of use (together with the documents referred to in it) tells you the terms of use on which you may make use of our website www.ttenvironmental.co.uk (our site), whether as a guest or a registered user. Use of - [Privacy Policy](https://ttenvironmental.co.uk/about-us/privacy-policy/) - This is the privacy notice of TT Environmental Ltd. We respect your privacy and are determined to protect your personal data. The purpose of this privacy notice is to inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from). We’ll also tell - [Cookies](https://ttenvironmental.co.uk/about-us/cookies/) - Information about our use of cookies. Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. [By continuing to browse the site, you are agreeing to our use of - [Shop](https://ttenvironmental.co.uk/shop/) - Welcome to TT Environmental’s shop. This is currently in the process of being updated, October 2017. If you have any queries about our products, please email info@ttenvironmenta.wpengine.com . Buy nowSevaluateSevaluateTM is an Excel based program which runs your COMAH (Seveso III) calculations for you, provides printable reports showing the main contributors to your COMAH liability, - [Library](https://ttenvironmental.co.uk/library/) - Welcome to TT Environmental’s content library, where you’ll find factsheets, tools and downloads to help you meet your chemical and environmental regulatory obligations. Some items can be used online or downloaded for free immediately, and some are supplied free after you provide your email address (which we never pass on to anyone else). Free DownloadEPR - [SevEstimate™](https://ttenvironmental.co.uk/comah/sevestimate/) - [Dossier Estimate](https://ttenvironmental.co.uk/reach/dossier-estimate/) - Use this free web calculator to estimate your REACH dossier costs, and check whether they are being shared in a fair way. This calculator may be useful for importers into the EU, or manufacturers within the EU, who are intending to register under the REACH Regulation as Member Registrants (non Lead Registrants). How to use - [REACH tonnage band calculator](https://ttenvironmental.co.uk/reach/reach-tonnage-band-calculator/) - Use this free web calculator to estimate your 3-year rolling averages for any substance which is REACH liable. Important note: the 3-year rolling average period ends on 31st December 2017. After this time, REACH liability for both unregistered and registered substances changes to the actual annual tonnage. The calculator can only be used retrospectively after - [Content restricted](https://ttenvironmental.co.uk/content-restricted/) - [wcm_content_restricted] - [Dossier Share](https://ttenvironmental.co.uk/reach/dossier-share/) - Dossier Share is an online software system for Lead Registrants and their administrators. It allows the costs of REACH data and associated administration costs to be shared between registrants of all types, with the ability to apply SME discounts if the SIEF agree to this. The program includes a full audit trail, so the administrator - [COMAH Liability](https://ttenvironmental.co.uk/comah/comah-liability/) - In order to work out if you will be in the scope of the COMAH 2015 Regulations, you will need to carry out an assessment based on the combination of hazardous properties (as described by CLP, or for Named Substances), and inventory. This is very similar to the calculations required under the COMAH 2005 Regulations, - [Land and Groundwater Modelling](https://ttenvironmental.co.uk/environmental-modelling/land-and-groundwater/) - You may need land and groundwater modelling for a variety of reasons, such as Environmental Permit or COMAH compliance, to predict the damage from a release to land, or to obtain Planning Permission. There are several types of land and groundwater modelling which may be carried out, including: The main program we use for soil - [Contaminated Land](https://ttenvironmental.co.uk/environmental-monitoring/contaminated-land/) - Contaminated Land services such as remediation and human health risk assessment are increasingly required by both industry and property developers as more is understood about the risks from contaminated land, and regulations become more stringent. Remediation of an industrial site may be required when an Environmental Permit is surrendered, or following an accidental release of - [Environmental Permit Surrender](https://ttenvironmental.co.uk/ippc-environmental-permit/permit-surrender/) - Once you’ve got your Environmental Permit, you can’t just walk away from the site. Selling your business means that the permit must be transferred to the new owners, and if you want to close, the permit must be surrendered to the relevant environment agency (EA, SEPA, NIEA, EAW), or in the case of Part A2 - [Environmental Monitoring Overview](https://ttenvironmental.co.uk/environmental-monitoring/) - Environmental projects often depend upon an element of site inspection or monitoring to provide: If you need help with Environmental Monitoring, contact Janet on 01422 24 22 22 or email Janet. - [Environmental Modelling Overview](https://ttenvironmental.co.uk/environmental-modelling/) - You may need environmental modelling for: - [CLI Notification](https://ttenvironmental.co.uk/clp/cli-notification/) - CLI is the Classification and Labelling Inventory, which is held on the European Chemicals Agency website. This is a reporting platform for all substances either manufactured by reaction in the EU, or imported into the EU. Substances can be products in their own right, or be contained within mixtures or formulations. Substances must be notified - [CLP Classification](https://ttenvironmental.co.uk/clp/clp-classification/) - CLP classification is different from CHIP in several aspects: How We Can Help We have several products and services to help you classify your products as accurately as possible with respect to CLP: If you need help with CLP classification, contact Janet on 01422 24 22 22, or email Janet. - [CLP Overview](https://ttenvironmental.co.uk/clp/) - CLP is the Classification, Labelling and Packaging Regulation, 2009, as amended. CLP is a directly-acting EU regulation, which means that it comes into effect across the EU without the need for national laws, like the REACH regulation. It is a new system for Classifying Labelling and Packaging chemicals for supply that is labelling for the - [Surface Water Monitoring](https://ttenvironmental.co.uk/environmental-monitoring/surface-water-monitoring/) - Surface water monitoring may be required routinely under Environmental Permit if you have a stream or river on or next your site. It may also be necessary if you have direct discharge of effluent into surface waters, although this is no longer common. Surface water monitoring can also be helpful as part of investigations following - [Environmental Permit Application](https://ttenvironmental.co.uk/ippc-environmental-permit/application/) - [Environmental Permit Site Reports](https://ttenvironmental.co.uk/ippc-environmental-permit/ippc-site-reports/) - Under the Environmental Permit Regulations, contamination and pollution of the environment is the prime concern. A Site Report is required for every Bespoke Environmental Permit site, and may also be required for Standard Rules Low Impact sites: - [Environmental Permit Compliance](https://ttenvironmental.co.uk/ippc-environmental-permit/compliance/) - Once you’ve got your Bespoke Environmental Permit, there may be additional one-off or ongoing technical or management conditions to meet, including: - [REACH](https://ttenvironmental.co.uk/reach/) - [Site Plans and Maps](https://ttenvironmental.co.uk/environmental-monitoring/site-plans-and-maps/) - [Environmental Monitoring Training](https://ttenvironmental.co.uk/environmental-monitoring/environmental-monitoring-training/) - Monitoring training can be carried out on your premises by our qualified and experienced staff. There are two aspects to environmental monitoring training: We are also happy to consider developing other environmental monitoring training courses. If you need help with Environmental Monitoring, contact Janet on 01422 24 22 22 or email email Janet. - [Site Inspection](https://ttenvironmental.co.uk/environmental-monitoring/site-inspection/) - Environmental projects for Permit and COMAH often require some form of site inspection or survey, including: In the case of potentially hazardous activities undertaken by sub-contractors, such as the drainage CCTV work where Confined Space Entry is likely to be required, we usually supervise personnel directly on site. We have close links with a core - [Land and Groundwater Monitoring](https://ttenvironmental.co.uk/environmental-monitoring/land-and-groundwater-monitoring/) - You may need land and groundwater monitoring for a variety of reasons, such as Environmental Permit or COMAH compliance, to track or remediate a spill, or to obtain Planning Permission (see our Contaminated Land page). Land and groundwater monitoring may include: - [Air and Odour Modelling](https://ttenvironmental.co.uk/environmental-modelling/air-and-odour-modelling/) - Air modelling may be required for applications under Environmental Permit, COMAH, and also for obtaining Planning Permission. As a first step, we recommend the use of the H1 software from the EA to screen air emissions from fixed points such as vents or stacks. This is sufficient to rule out insignificant emissions to the regulator’s - [Air and Odour Monitoring](https://ttenvironmental.co.uk/environmental-monitoring/air-and-odour-monitoring/) - Environmental air monitoring is usually required for Environmental Permit compliance purposes. Air monitoring can also be required for health surveillance of the workforce, to ensure that the Workplace Exposure Limits (WELs) for certain hazardous materials are not being exceeded, to protect your staff’s health. Odour monitoring may also be required for Permit compliance (EA), or - [Surface Water Modelling](https://ttenvironmental.co.uk/environmental-modelling/surface-water-modelling/) - Surface water modelling is generally required for: For other aquatic environments, the Environment Agency have approved a variety of free and commercial estuary and marine models, and we are happy to use them where appropriate. We have also developed in-house models for estimating pollutant migration through narrow “bottle shaped” estuaries, and from this estuary type - [Energy Release Modelling](https://ttenvironmental.co.uk/environmental-modelling/energy-release-modelling/) - As part of your COMAH risk assessments, you may need to predict what would happen to people and the environment if there is a fire or explosion at your site. We offer energy release modelling based on the US EPA RMP calculations as follows: US EPA energy calculations tend to be to a fixed end - [COMAH Overview](https://ttenvironmental.co.uk/comah/) - The main aim of the COMAH regulations is to prevent, control and mitigate the effects of accidents involving chemicals that could cause serious harm to people and/or the environment. Typical types of Major Accidents that are covered by COMAH include fires, explosions, toxic gas releases, and leaks of hazardous substances to rivers and land. The - [Upper Tier COMAH](https://ttenvironmental.co.uk/comah/upper-tier-comah/) - For Upper Tier COMAH, a Safety Report is required which usually includes: External Links - [COMAH Notification](https://ttenvironmental.co.uk/comah/comah-notification/) - COMAH Notification during 2015 – 2016 phase in period. COMAH notification is more complicated than usual during the 2015 – 2016 transition period. Firstly, you need to work out whether you are liable for COMAH under the 2015 Regulations (see our COMAH liability page). - [COMAH ERA](https://ttenvironmental.co.uk/comah/comah-era/) - A COMAH Environmental Risk Assessment (ERA) is required for both Upper Tier and Lower Tier sites. Upper Tier sites are required to submit their ERA for formal inspection and review to the Competent Authority (HSE and relevant Environment Agency), either as part of the Safety Report, or as a stand-alone document. Lower Tier sites are - [COMAH Lower Tier](https://ttenvironmental.co.uk/comah/lower-tier-comah/) - A site that falls within Lower Tier COMAH must supply basic details to the Competent Authority (full details are given in Schedule 3 of the Regulations). Normally, if a site is entering Lower Tier COMAH, the rules on when notification must be made to the HSE are quite straightforward. However, in the period from 1st - [Newsletter: Thank You](https://ttenvironmental.co.uk/newsletter-thank-you/) - Thank you for subscribing to our newsletter! You should receive an email from us, please click on the link in the email to confirm your subscription and start receiving news. - [Sevaluate: Thank You](https://ttenvironmental.co.uk/sevaluate-thank-you/) - Thank you for subscribing to news about SevaluateTM, the COMAH liability calculation software. You should receive an email from us, please click on the link in the email to confirm your subscription and receive this news. - [COMAH: Thank You](https://ttenvironmental.co.uk/thank-you-comah/) - Thank you for requesting the COMAH Toolkit, you can download the files individually from this page or together as a zip file. You will also receive an email confirming your subscription to our newsletter. COMAH Liability Toolkit COMAH Factsheet 2015 v2 COMAH Factsheet 2015 v2 Should you control your inventory to avoid COMAH or stay in - [EP: Thank You](https://ttenvironmental.co.uk/thank-you/) - Thank you for requesting the Environmental Permit Application Toolkit, you can download the files individually from this page or together as a zip file. You will also receive an email confirming your subscription to our newsletter. Do you need to have intrusive ground investigations under Environmental Permit Do you need to hold ISO14001 or EMAS - [Chemical Regulations Self Help Group](https://ttenvironmental.co.uk/reach/chemical-regulations-self-help-group/) - The Chemical Regulations Self Help Group is a discussion group for companies active in the chemical supply chain, and a few trusted advisors. We meet quarterly for a structured discussion on REACH and CLP issues, and include other chemical regulations such as Biocides, COMAH, nano regulations etc. Members are encouraged to put forward questions and - [Intrusive Ground Investigations](https://ttenvironmental.co.uk/intrusive-ground-investigations/) - Thank you for registering with us for your free white paper. Please download it here; Intrusive Ground Investigations White Paper. - [Get Response Form Test](https://ttenvironmental.co.uk/get-response-form-test/) - Code sent to Jenny 28/10/15 at 12:0015:28 ## Memberships - [CLP Knowledgebase](https://ttenvironmental.co.uk/register/clp-knowledgebase/) ## Knowledgebase - [Environmental hazard classification of mixtures](https://ttenvironmental.co.uk/clp-knowledgebase/environmental-hazard-classification-of-mixtures/) - The classification of environmental hazards of mixtures should be made on the basis of test data, where it exists. However, tests on animals are to be avoided where at all possible, and this means that vertebrate tests on aquatic toxicity, that is fish testing, should be avoided where possible. To overcome this difficulty, CLP includes a - [Mixture classification forms](https://ttenvironmental.co.uk/clp-knowledgebase/mixture-classification-forms/) - Mixture classification forms are mainly for health and environmental hazards. However, there are some physical hazards of mixtures which can be assessed without requiring tests. Mixture Summary forms Mixture-component-form-v2.1-01-03-2017 Checking-for-new-substance-formation-in-a-mixture Screening questions for physical hazards of mixtures v1.3 03-02-2018 Hazardous-substance-component-identification-form v1.3 23-01-2018 Physical hazards of mixtures Physical hazards of mixtures screening form: Screening questions for physical - [Chemical structures](https://ttenvironmental.co.uk/clp-knowledgebase/chemical-structures/) - A chemical structure (or structural formula) can be used to check that a chemical is what the name says, or to identify different isomers which may have different chemical properties. A chemical structure shows the layout of a molecule, including the position of the elements and type of bonding. There is more than one convention - [What is CLP?](https://ttenvironmental.co.uk/clp-knowledgebase/what-is-clp/) - Definition of CLP CLP is an EU regulation covering the Classification Labelling and Packaging of chemical materials for supply. The current consolidated version of the CLP Regulation (last updated 1st March 2018) is available from here: CLP consolidated version 1st March 2018 to 9th ATP and CHIP HCs removed. As you can tell from the description - [CLP Health Hazards](https://ttenvironmental.co.uk/clp-knowledgebase/clp-health-hazards/) - There are a number of specific health hazards from chemicals covered by CLP-GHS. The effects include "systemic toxicity", that is whole-body poisoning effects (which can cover a wide range of effects from feeling mildly unwell to dying) through: inhalation (breathing in the chemical) ingestion (swallowing the chemical) skin contact (touching the chemical, being splashed by - [P Statement printables](https://ttenvironmental.co.uk/clp-knowledgebase/p-statement-printables/) - P Statements by group (A3 poster): P statements by group 18-04-2018 . - [Information precedence for CLP](https://ttenvironmental.co.uk/clp-knowledgebase/information-precedence-for-clp/) - Information precedence, that is placing some information on the label and leaving other information off, is applied to labels for four separate pieces of information: Signal Word precedence Pictogram (symbol) precedence H Statement precedence P Statement precedence Precedence of information is worked out when you generate CLP label information, see https://ttenvironmenta.wpengine.com/clp-knowledgebase/generating-clp-label-information/ , in particular on the - [P Statements](https://ttenvironmental.co.uk/clp-knowledgebase/p-statements/) - Precautionary Statements, P Statements, are part of GHS, like the pictograms, signal word and H Statements. Precautionary Statements, as the name suggests, include information on how the handle the product under normal conditions, and what to do in an incident. There are 5 types of P statement, as follows: P100s - only for consumer products - [H Statements](https://ttenvironmental.co.uk/clp-knowledgebase/h-statements/) - Hazard Statements, or H Statements are part of the labelling information within GHS and CLP. The short codes (H200 etc), which refer to the H Statement text, are considered to be part of the classification, see https://ttenvironmenta.wpengine.com/clp-knowledgebase/clp-ghs-classifications/ . The full classification information does NOT appear on the label (unless it is placed there voluntarily), only the H - [Generating CLP label information](https://ttenvironmental.co.uk/clp-knowledgebase/generating-clp-label-information/) - Once you have obtained your CLP classification, you need to use it to provide you with all of the rest of the CLP-GHS information for the product label. This is done by using the look-up tables provided in the GHS-CLP Classification Summary Sheets here: GHS-CLP Classification Summary Sheets v2.4 . The amount of labelling information required varies, - [CLP-GHS classifications](https://ttenvironmental.co.uk/clp-knowledgebase/clp-ghs-classifications/) - Definition of CLP classification There is no formal definition of what a GHS classification actually is, and this lack of definition appears to have been adopted within CLP as well. This is rather unsatisfactory because it does not make legally clear what is being discussed, or what is required of someone classifying, labelling and writing - [H Statement Printables](https://ttenvironmental.co.uk/clp-knowledgebase/h-statement-printables/) - Comparison of CLP and GHS H Statements (A3 poster): GHS classifications and whether adopted into CLP v2.3 . - [GHS within CLP](https://ttenvironmental.co.uk/clp-knowledgebase/ghs-within-clp/) - The parts of GHS held within CLP are: most of the classifications themselves labelling information for the GHS classifications - symbols, Signal Word, H Statements and P Statements some of the chemical identifiers to be use, eg CAS numbers, substance or trade names packaging information A comparison of the classifications and hazard statements held within - [About GHS](https://ttenvironmental.co.uk/clp-knowledgebase/about-ghs/) - GHS is the Globally Harmonised System of Classification and Labelling of Chemicals. The underlying idea is that if everyone in the world classifies and labels their chemicals for supply in the same way, it will be much safer for the end user, and also promote international trade in chemicals. The UN have already brought in - [Acronyms in the CLP Knowledgebase](https://ttenvironmental.co.uk/clp-knowledgebase/acronyms-in-the-clp-knowledgebase/) - There are a lot of acronyms used in chemical classification systems, so here are some of the main ones you may encounter in this knowledgebase: ADR European Agreement concerning the International Carriage of Dangerous Goods by Road ATE Acute Toxicity Estimate. Concept used in the classification of acute toxic hazards to human health (fatal or - [Small package labelling](https://ttenvironmental.co.uk/clp-knowledgebase/small-package-labelling/) - Under CLP (and GHS), it is permitted to have smaller labels (sometimes containing less information) on: all packages between 125 ml and 3 litres all packages between 10 ml and 125 ml industrial and professional use packages for QC and R&D purposes less than 10 ml Notes: the sizes refer to the volume of the - [List of amendments to CLP Knowledgebase](https://ttenvironmental.co.uk/clp-knowledgebase/list-of-amendments-to-clp-knowledgebase/) - The current list of amendments is shown below, most recent batch of changes are shown in red. - [Section 1 of the SDS](https://ttenvironmental.co.uk/clp-knowledgebase/section-1-of-the-sds/) - In the SDS, SECTION 1: Identification of the substance/mixture and of the company/undertaking comprises: 1.1 Product identifier 1.2 Relevant identified uses of the substance or mixture and uses advised against 1.3 Details of the supplier of the safety data sheet 1.4 Emergency telephone number Section 1 of an SDS should be on the first page of - [UK Poison Centre Notification](https://ttenvironmental.co.uk/clp-knowledgebase/uk-poison-centre-notification/) - At the time of writing, February 2018, the UK Poison Centres are run by the National Poisons Information Service, NPIS, which is headquartered in Birmingham but has several other offices. To notify a product to the UK Poison Centre, you need to send them an email with your product SDS. At the time of writing, - [CLP label layout](https://ttenvironmental.co.uk/clp-knowledgebase/clp-label-layout/) - CLP labels are required on the individual package, and on outer packs as well, see https://ttenvironmenta.wpengine.com/clp-knowledgebase/packages-requiring-clp-labels/ . CLP labels can contain CLP information alone, or include extra non-CLP information (such as lot or batch numbers, or date of manufacture etc); or they can be a dual label with Transport information, which is often used for industrial - [Useful information](https://ttenvironmental.co.uk/clp-knowledgebase/useful-information/) - ECHA CLP guidance (several guides on classification, labelling, substance identification etc.) https://echa.europa.eu/guidance-documents/guidance-on-clp ECHA REACH guidance (several guides on SDSs, REACH registration, substances in articles etc.) https://echa.europa.eu/guidance-documents/guidance-on-reach HSE Helpdesk webpage http://www.hse.gov.uk/reach/helpdesk.htm HSE Helpdesk email (REACH and CLP only – separate biocides helpdesk) UKREACHCA@hse.gov.uk HSE Bookshop https://books.hse.gov.uk/hse/public/home.jsf Chemical Regulations Self Help Group (quarterly discussion group - [CLP Pictogram Printables](https://ttenvironmental.co.uk/clp-knowledgebase/clp-pictogram-printables/) - GHS-CLP Pictograms poster: GHS-CLP-Pictograms-poster Comparison of CLP pictograms with CHIP symbols (mini poster): GHS-CLP-Pictograms-and-CHIP-Symbols CLP Pictograms with associated H Codes (mini poster): CLP symbols with H codes A4 CLP Pictograms or symbols in Word at different sizes to use on labels printed in-house: CLP Pictograms in word for in-house labels 2 - [CLP Pictograms (Symbols)](https://ttenvironmental.co.uk/clp-knowledgebase/clp-pictograms-symbols/) - There are 9 CLP Pictograms (or symbols to normal people, although technically under CLP-GHS-speak the symbol is the internal image in the overall pictogram). The CLP Pictograms are all derived from GHS, and comprise a diamond shape with a white background and a bright red border, surrounding an internal symbol. The symbols can be downloaded as a - [Mixtures with confidential component substances](https://ttenvironmental.co.uk/clp-knowledgebase/mixtures-with-confidential-component-substances/) - Under CHIP, and now under CLP, certain components in a mixture are allowed to use an alternative chemical name, and to omit the identification numbers from the SDS, so that the confidentiality of the mixture recipe can be maintained. However, the % w/w (actual, or in a range), and the CLP classification of the confidential - [Consumer products](https://ttenvironmental.co.uk/clp-knowledgebase/consumer-products/) - Products which are supplied to consumers have specific requirements over and above those for professional and industrial users. These requirements may include: P statements for consumers Tactile Warning Labels Child Resistant Packaging No need to supply a consumer with a Safety Data Sheet Small packaging label information Other packaging requirements for consumer products Advertising hazardous - [Pro forma Safety Data Sheets](https://ttenvironmental.co.uk/clp-knowledgebase/pro-forma-safety-data-sheets/) - To help you if you need to write an SDS in-house, we have complied two pro-forma SDSs in word, which you can save to your laptop and fill in with the appropriate information for your products. Before filling in either of the pro formas, we recommend you read the rest of the SDS information held - [Safety Data Sheet layout](https://ttenvironmental.co.uk/clp-knowledgebase/safety-data-sheet-layout/) - The layout of Safety Data Sheets (SDSs) is given in REACH Annex II and comprises 16 sections, and a further 49 sub-sections and an Annex (for REACH registered substances). These headings and sub-sections cannot be omitted from a Safety Data Sheet, apart from either Section 3.1 or 3.2, which is for either Substances or Mixtures - [Products requiring SDSs](https://ttenvironmental.co.uk/clp-knowledgebase/products-requiring-sdss/) - Safety Data Sheets are required for specific chemical products for all Industrial and some Professional users. They are not required for consumers. The reason for this is that consumers are unlikely to be exposed to hazardous materials to the same extent as industrial and professional users, who require extra information to ensure they are using - [Pro forma CLP labels](https://ttenvironmental.co.uk/clp-knowledgebase/pro-forma-clp-labels/) - We have made some CLP pro forma labels in Word for you to use if you are printing labels in-house (e.g. for lab samples etc): A5 Pro forma label v2 02-02-2018 A6 Pro forma label v2 02-02-2018 A7 Pro forma label v2 02-02-2018 A8 Pro forma label v2 02-02-2018 A8 Pro forma label 10mm symbol - [Packages requiring CLP labels](https://ttenvironmental.co.uk/clp-knowledgebase/packages-requiring-clp-labels/) - Any product which is classified as hazardous under CLP requires a CLP label under Article 33, as follows: Single package, not labelled for Transport – CLP label only Single package, labelled for Transport – CLP label and Transport label, or dual CLP/Transport label Package with inner and outer packaging, outer not labelled for Transport – - [Labelling printables](https://ttenvironmental.co.uk/clp-knowledgebase/labelling-printables/) - Pack size: Package volume defines CLP label and symbol size Packaging and symbol size together: Label and symbol minimum sizes to scale Label content infographic: CLP label content Tactile packaging/ child resistant packaging: Hazards triggering tactile warnings and child resistant fastenings - [CLP Label Content](https://ttenvironmental.co.uk/clp-knowledgebase/clp-label-content/) - The content of CLP labels for most package sizes is given in the CLP regulation as being: Supplier information - Name, address, telephone number. This should be the details of the person supplying the product in the EU, and will therefore be an EU address and telephone number. Other address and phone numbers (e.g. for - [EUH classification sequence](https://ttenvironmental.co.uk/clp-knowledgebase/euh-classification-sequence/) - EUH Statements are a not a consistent group of instructions. Some are hazard classifications, and others provide information (e.g.that an SDS is available on request). This means that the EUH statements are classifiable in different ways, and also that more than one may apply to your product. The sequence for EUH Statement classification is: Identify - [Health hazard classification of mixtures](https://ttenvironmental.co.uk/clp-knowledgebase/health-hazard-classification-of-mixtures/) - In general the classification of hazards should be made on the basis of test data, where it exists. However, tests on animals are to be avoided where at all possible, which creates a problem for health hazards, as these are mainly identified through animal testing. To overcome this difficulty, CLP includes a series of options - [About CLP classification for mixtures](https://ttenvironmental.co.uk/clp-knowledgebase/about-clp-classification-for-mixtures/) - The overall CLP classification sequence for mixtures is: identify all component substances, and calculate their exact quantities in the mixture (e.g. if a mixture containing 20% of a substance is used at 50% in the final mixture, the quantity of the substance in the mixture is 10%) check that your mixture does not contain any new - [The CLP Classification Sequence](https://ttenvironmental.co.uk/clp-knowledgebase/the-clp-classification-sequence/) - When you set out to classify a product for CLP, it can be easy to dive straight into classifying from first principles, but this may not be the best approach. There is a lot of information available to you, particularly for substances, which you should use first, rather than thinking you need to do all - [First principle classification forms](https://ttenvironmental.co.uk/clp-knowledgebase/first-principle-classification-forms/) - Classification forms for first principles classification: First principles classification summary form: Classifying products from First Principles summary form . Physical hazards Physical hazards of substances screening form: Screening questions for substance physical hazards v1.2 . Physical hazard classification forms, first principles: First Principles Explosives Classification First Principles Flammable Gases First Principles Aerosols First Principles Flammable Liquids First Principles Flammable - [CLP environmental hazard classification from first principles](https://ttenvironmental.co.uk/clp-knowledgebase/clp-environmental-hazard-classification-from-first-principles/) - CLP environmental hazards require test data to allow classification of substances. Environmental hazards of mixtures can be classified by calculation, to avoid unnecessary testing of fish (which are vertebrate animals), see https://ttenvironmenta.wpengine.com/clp-knowledgebase/environmental-hazard-classification-of-mixtures/ . Environmental hazard tests are discussed here: https://ttenvironmenta.wpengine.com/clp-knowledgebase/clp-environmental-hazard-tests/ . Forms for classifying environmental hazards from first principles based on test data: First Principles Acute aquatic toxicity First - [CLP health hazard classification from first principles](https://ttenvironmental.co.uk/clp-knowledgebase/clp-health-hazard-classification-from-first-principles/) - CLP health hazards require test data to allow classification of substances. Health hazards of mixtures can be classified by calculation, to avoid unnecessary animal testing, see https://ttenvironmenta.wpengine.com/clp-knowledgebase/health-hazard-classification-of-mixtures/ . Health hazard tests are discussed here: https://ttenvironmenta.wpengine.com/clp-knowledgebase/clp-health-hazard-tests/. First Principles Acute Oral Toxicity First Principles Aspiration Toxicity First Principles Acute Dermal Toxicity First Principles Skin corrosion and irritancy First - [CLP physical hazard classification from first principles](https://ttenvironmental.co.uk/clp-knowledgebase/clp-physical-hazard-classification-from-first-principles/) - CLP physical hazards generally require test data to allow classification. This applies to both substances and mixtures (where test data exists). For mixtures which can be classified by calculation, see https://ttenvironmenta.wpengine.com/clp-knowledgebase/physical-hazard-classification-of-mixtures/ , however these methods should only be used where no test data on the mixture has been generated. CLP physical hazard tests are discussed here: https://ttenvironmenta.wpengine.com/clp-knowledgebase/clp-physical-hazard-tests/ - [About CLP Classification from First Principles](https://ttenvironmental.co.uk/clp-knowledgebase/about-clp-classification-from-first-principles/) - CLP classification from first principles is used to classify substances and mixtures on the basis of test data, for most hazards, and human experience for some specific health hazards. Normally, substance classification is carried out during the REACH registration process for novel chemicals, or when existing substances are registered. However, in some circumstances, such as - [CLP Environmental Hazards](https://ttenvironmental.co.uk/clp-knowledgebase/clp-environmental-hazards/) - There are only a few environmental hazards from chemicals covered by CLP-GHS, which are: short term (acute) aquatic toxicity long term (chronic) aquatic toxicity Aquatic toxicity covers hazards to fish, aquatic invertebrates, and aquatic plants. Strictly speaking, hazards to the ozone layer are classed as "other hazards" under CLP, but for practical purposes we have - [CLP Physical Hazards](https://ttenvironmental.co.uk/clp-knowledgebase/clp-physical-hazards/) - There are a number of specific physical hazards from chemicals covered by CLP-GHS. These are often described in combination with the physical form of the material, e.g. flammable aerosol, flammable gas, flammable solid etc. These include explosives flammable gas flammable solid flammable liquid and vapour (including CLP-only flammables, EUH statements) flammable and non-flammable aerosol oxidising gas - [CLP physical hazard tests](https://ttenvironmental.co.uk/clp-knowledgebase/clp-physical-hazard-tests/) - CLP physical hazard tests are identical for both substances and mixtures. These tests are mainly derived from Transport, see Manual of Tests and Criteria Rev 6 2015 . You should only need to carry out physical tests on substances which are not registered for REACH, or where you are required to derive the CLP classification yourself (e.g. - [Physical hazard classification of mixtures](https://ttenvironmental.co.uk/clp-knowledgebase/physical-hazard-classification-of-mixtures/) - Once you have identified all of the component substances in a mixture, the physical hazards can be derived from: the physical properties of the component substances and any new physical hazards which have been created by mixing incompatible materials together The document on screening physical hazards of mixtures will enable you to identify which physical - [About tests for CLP classification](https://ttenvironmental.co.uk/clp-knowledgebase/about-tests-for-clp-classification/) - Tests on substances or mixtures are only required where there is no other reliable source of information to enable a classification to be made. The tests are the same for both substances or mixtures. The tests are split by hazard type into: physical hazard tests, see: https://ttenvironmenta.wpengine.com/clp-knowledgebase/clp-physical-hazard-tests/ health hazard tests, see: https://ttenvironmenta.wpengine.com/clp-knowledgebase/clp-health-hazard-tests/ environmental hazard tests, see: https://ttenvironmenta.wpengine.com/clp-knowledgebase/clp-environmental-hazard-tests/ There are - [Safety Data Sheet languages](https://ttenvironmental.co.uk/clp-knowledgebase/safety-data-sheet-languages/) - The language of the Safety Data Sheet (SDS) should be an official language of the country where the product is supplied, subject to the requirements of the local Competent Authority. It is legal to have more than one language on the SDS, but in practice this is rarely done, as it is usually much simpler to - [Finding published data on substances](https://ttenvironmental.co.uk/clp-knowledgebase/finding-published-data-on-substances/) - There are numerous sources of published data on chemical substances, including: Chemical textbooks Regulator's online inventories Commercial online inventories Scientific papers Safety Data Sheets Chemical textbooks Chemical textbooks often include basic physical and chemical information on substances which can be useful for classification purposes, and information on chemical reactions and storage hazards which are useful - [Procedure for classifying substances](https://ttenvironmental.co.uk/clp-knowledgebase/procedure-for-classifying-substances/) - Where you haven't got a published classification for your substance and you have to classify from scratch, there are two different procedures, one for physical hazards and another for the health and environmental hazards. Procedure for classifying physical hazards of substances Based on the chemistry of the substance, screen out non-relevant physical hazards (this should - [Converting Transport classifications to CLP](https://ttenvironmental.co.uk/clp-knowledgebase/converting-transport-classifications-to-clp/) - Many transport classifications are directly equivalent to CLP classifications, and a series of tables showing these equivalent classifications is given in GHS, in Annex 1. A copy is available here for reference: Annex 1 to GHS Rev 7 with transport equivalents. In some cases, a Transport classification may have more than one CLP hazard, and this - [Converting GHS classifications to CLP](https://ttenvironmental.co.uk/clp-knowledgebase/converting-ghs-classifications-to-clp/) - A substance or mixture which has been classified for GHS outside the EU is likely to be relatively easy to convert to CLP, as long as it is not a substance which holds a Harmonised Classification in the non-EU country. You can also download this flowchart as a pdf: Routes for converting a GHS classification into - [Classification comparison forms](https://ttenvironmental.co.uk/clp-knowledgebase/classification-comparison-forms/) - There is a single form for comparing classifications, whether based on CLP or GHS: Classification comparison form This form is a simple table to allow you to view different classifications side-by-side, and help you arrive at a decision on what the overall classification of a substance or mixture should be. Don't forget to attach your - [Comparing published CLP classifications](https://ttenvironmental.co.uk/clp-knowledgebase/comparing-published-clp-classifications/) - It is possible to have different published CLP classifications from several sources, including: Harmonised Classifications and the REACH dossier CLI entries CLI entries and Safety Data Sheet classifications from reputable suppliers The information in these classifications may need to be compared to enable you to take a decision on the classification as a whole. Reliability - [How to read CLP classifications notified to the C&L Inventory](https://ttenvironmental.co.uk/clp-knowledgebase/how-to-read-clp-classifications-notified-to-the-c-and-l-inventory/) - CLP classifications notified to the Classification and Label (C&L) Inventory can be accessed directly by searching the inventory itself, or by carrying out a chemical search from the first page of the ECHA website. Whichever route you use, the C&L Inventory page for that substance will appear on screen. The C & L inventory overall - [CLP classifications on the C&L Inventory](https://ttenvironmental.co.uk/clp-knowledgebase/clp-classifications-on-the-cl-inventory/) - As part of the CLP Regulation, ECHA requires that everybody notifies the CLP classifications of any substance made or imported into the EU, in any quantity, to the Classification and Labelling Inventory (CLI). This means that there is a repository of CLP classifications published by ECHA and available to view online at https://echa.europa.eu/information-on-chemicals/cl-inventory-database . However, there are - [How to read CLP classifications in REACH dossiers](https://ttenvironmental.co.uk/clp-knowledgebase/how-to-read-clp-classifications-in-reach-dossiers/) - CLP classifications can be read directly from the REACH dossiers. Before using the classification, you may need to consider whether the REACH dossier is good quality, see: Is a REACH dossier good quality. Some substances have more than one REACH dossier, when you will need to choose which dossier to view. Once you have brought up the REACH - [How to read Harmonised Classifications](https://ttenvironmental.co.uk/clp-knowledgebase/how-to-read-harmonised-classifications/) - There are two aspects to reading Harmonised Classifications: getting information from the published Harmonised Classification list being aware of some of the snags with the published Harmonised Classification list The good news is that Harmonised Classifications always take the same format, regardless of whether they are published in print, or online as part of the Classification - [Finding CLP classifications on the ECHA website](https://ttenvironmental.co.uk/clp-knowledgebase/finding-clp-classifications-on-the-echa-website/) - There are several routes to finding CLP classifications on the ECHA website: The REACH dossiers can be accessed directly from https://echa.europa.eu/information-on-chemicals/registered-substances . The Classification and Labelling Inventory can be accessed directly from https://echa.europa.eu/information-on-chemicals/cl-inventory-database . The chemical search box on the front page of the ECHA website at https://echa.europa.eu/ . Generally, the chemical search box is the easiest way to - [IARC Carcinogen List](https://ttenvironmental.co.uk/clp-knowledgebase/iarc-carcinogen-list/) - The IARC (International Agency for Research on Cancer) publish a list of known and suspected carcinogens, in a series of Monographs, for details of their work see http://www.iarc.fr/. Under the IARC carcinogenicity classification, there are Category 1A and 1B, Category 2, and Category 3 Carcinogens. The list of IARC carcinogens does not match the CLP/ - [Nano materials](https://ttenvironmental.co.uk/clp-knowledgebase/nano-materials/) - Nano materials are not a specific hazard class within GHS or within CLP. In the EU, nano materials are required to be described as such in REACH registrations, see https://echa.europa.eu/-/reach-guidance-for-nanomaterials-published . ECHA have also launched a "nanomaterials observatory" in June 2017, https://euon.echa.europa.eu/, to provide people with information on nano materials in the EU, which may be a - [Prior Informed Consent substances](https://ttenvironmental.co.uk/clp-knowledgebase/prior-informed-consent-substances/) - Prior Informed Consent is require to import or export certain substances, whether they are sold as-is or in mixtures, under the Rotterdam Convention, http://www.pic.int/. It is regulated in the EU through Regulation (EU) 649/2012, http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32012R0649&from=EN . PIC, including consent to export, is managed through ECHA, for details see https://echa.europa.eu/regulations/prior-informed-consent/legislation . The PIC Regulation contains three - [Lead containing products](https://ttenvironmental.co.uk/clp-knowledgebase/lead-containing-products/) - Lead metal and lead compounds are known to be particularly toxic to humans if ingested or inhaled in small concentrations. Lead, its compounds, and mixtures containing lead or lead compounds are covered by a specific Workplace Exposure Limit for lead. However this is not listed in EH40, but instead sits in the Control of Lead - [Section 8 of the SDS](https://ttenvironmental.co.uk/clp-knowledgebase/section-8-of-the-sds/) - In the SDS, SECTION 8: Exposure controls/personal protection comprises: 8.1. Control parameters 8.2. Exposure controls When completing this section of the SDS, you may find it useful to speak to an occupational health expert such as your on-site Health and Safety Manager, or an external consultant, if you use one. It will be more helpful if this - [Chemicals with Workplace Exposure Limits](https://ttenvironmental.co.uk/clp-knowledgebase/chemicals-with-workplace-exposure-limits/) - Many chemicals have Workplace Exposure Limits (WELs), also sometimes referred to as Occupational Exposure Limits (OELs) in the UK. These can be exposure limits for the concentrations and exposure time for inhalation, or dermal contact. Biological limit values, e.g. quantity of a substance in the bloodstream, may also be given. There are two types of WEL, EU WELs, and - [Restricted chemicals](https://ttenvironmental.co.uk/clp-knowledgebase/restricted-chemicals/) - Restrictions limit or ban the manufacture, placing on the market or use of certain substances that pose an unacceptable risk to human health and the environment. (They are different from SVHCs in that the EU is not usually trying to phase out their use completely, although some total bans do exist). Restrictions on chemicals, that is - [Authorisation List](https://ttenvironmental.co.uk/clp-knowledgebase/authorisation-list/) - The Authorisation List comprises those substances which started out as Substances of Very High Concern, and which have been deemed to be so hazardous that they can only be handled in the EU under a special licence. The ultimate aim of Authorisation is to remove the chemicals from the EU marketplace entirely, and this is - [SVHC List](https://ttenvironmental.co.uk/clp-knowledgebase/svhc-list/) - Identifying an SVHC is the first step in the Authorisation process. The point of the Authorisation process is to remove substances from the EU supply chain entirely, unlike restriction, where the point is usually to allow substances to be used under conditions which will reduce the risk to humans and/or the environment across the EU. A - [Index numbers](https://ttenvironmental.co.uk/clp-knowledgebase/index-numbers/) - Index numbers are used to identify specific chemical substances which hold a Harmonised Classification in the EU. This means that not every chemical on the market will have an Index number. They are valid for identifying chemical substances on CLP labels and on the Safety Data Sheet. Index numbers take the form of XXX-XXX-XX-X. They are published in - [Chemical names](https://ttenvironmental.co.uk/clp-knowledgebase/chemical-names/) - There are a number of different chemical naming systems, both formal and informal, which are used in industry and by the general public. This can make chemical identification complex. There is an official naming system, IUPAC, the International Union of Pure and Applied Chemistry, which covers inorganic and organic chemical substances. The IUPAC system is - [The Signal Word](https://ttenvironmental.co.uk/clp-knowledgebase/the-signal-word/) - The Signal Word is used on a CLP/ GHS label to convey the overall level of severity of the product. This means there is only one Signal Word per label. There are three levels of severity: Danger (most severe hazard) Warning (medium hazard) No signal word placed on the label (low hazard) Note that if - [Product Identifiers](https://ttenvironmental.co.uk/clp-knowledgebase/product-identifiers/) - Substances and mixtures have different product identifiers for the CLP label. Some component substances in mixtures may be required to be named on the label. These and other component substances may require full identification on the Safety Data Sheet (SDS). Product identifiers for substances on labels Substances sold alone (or in dilution) are required to - [When and what to notify to the C&L Inventory](https://ttenvironmental.co.uk/clp-knowledgebase/when-and-what-to-notify-to-the-c-and-l-inventory/) - Companies or natural persons are legally obliged to notify any substance they make or import into the EU to the Classification and Labelling (C&L) Inventory within 30 days of first manufacture or import. Substances can be: pure substances (or with impurities) contained in mixtures contained in articles Mixtures and articles are not notified to the - [EUH Statements](https://ttenvironmental.co.uk/clp-knowledgebase/euh-statements/) - CLP requires some hazard information to be placed on CLP labels for materials with hazards not currently covered under GHS. These hazards are called EUH Statements, although they are not officially part of the CLP-GHS classification. EUH Statements do not generate any GHS symbols, (with the exception of EUH071, which can generate the corrosive symbol), - [How to notify to the C&L Inventory](https://ttenvironmental.co.uk/clp-knowledgebase/how-to-notify-to-the-c-and-l-inventory/) - Notification to the C&L Inventory is made using the REACH-IT system on the ECHA website. Notification is free (apart from the time you need to do this), and obtaining a REACH-IT log-in is also free. If you have pre-registered a substance for REACH, you will already have a REACH-IT log-in. REACH-IT can be accessed from - [Hazards not included in CLP](https://ttenvironmental.co.uk/clp-knowledgebase/hazards-not-included-in-clp/) - Some hazards are currently ignored under CLP. This does not mean that they do not exist, but that they are not identified on the label. It is possible to identify these hazards on the Safety Data Sheet (and sometimes on the CLP label as "supplementary information"), and it is considered good practice to include information - [Transport and CLP](https://ttenvironmental.co.uk/clp-knowledgebase/transport-and-clp/) - There are three areas of "overlap" between Transport and CLP: They cover many of the same hazards, tested using the same criteria with the same thresholds, so many classifications are equivalent Some packages have to be labelled for both systems Transport information is required on the SDS in Section 14 Hazards and their classification in - [About REACH](https://ttenvironmental.co.uk/clp-knowledgebase/about-reach/) - The REACH regulation (Registration, Evaluation, Authorisation and Restriction of Chemicals) is an EU directly-acting regulation, like CLP. In fact, when it was introduced in 2006, it was the first directly-acting regulation through the whole of the EU. The primary purpose of REACH is to ensure that every chemical on the EU marketplace has been subjected - [Where supply chain communication is required without an SDS](https://ttenvironmental.co.uk/clp-knowledgebase/where-supply-chain-communication-is-required-without-an-sds/) - There are some chemical products which do not require an SDS, but which still have supply chain communication requirements under Article 32 of REACH. Similarly, under Article 33 of REACH, articles containing Authorised Substances have supply chain communication requirements. REACH Article 32 products REACH article 32 covers substances or mixtures which do not otherwise require - [About Safety Data Sheets](https://ttenvironmental.co.uk/clp-knowledgebase/about-safety-data-sheets/) - The Safety Data Sheet (SDS) is a technical document listing the identity of a substance or mixture; the CLP/ GHS hazards of the product, and any CLP EUH statements on the label; information on the physical and chemical properties of the product; information on the physical, health and environmental hazards of the product; and advice - [Toll manufactured products](https://ttenvironmental.co.uk/clp-knowledgebase/toll-manufactured-products/) - There is some debate within the chemical industry about who is responsible for classifying, labelling and providing SDSs for toll-manufactured products. Strictly speaking, if the toll manufacturing company is placing a hazardous product on the market by selling it to their customer, then the toll company is responsible for this information being generated and supplied. - [Vaping and e-liquids](https://ttenvironmental.co.uk/clp-knowledgebase/vaping-and-e-liquids/) - "Vaping", that is the vapour inhalation of liquids containing nicotine and flavours from an electronic cigarette ("e-cigarette"), as an alternative to smoking tobacco, has grown into a large industry since it was introduced in its modern format into Europe in 2006. The liquids consumed in an "e-cigarette" are often referred to as "e-liquids", by vapers - [Section 14 of the SDS](https://ttenvironmental.co.uk/clp-knowledgebase/section-14-of-the-sds/) - 14 Transport information The sub-sections are: 14.1. UN number 14.2. UN proper shipping name 14.3. Transport hazard class(es) 14.4. Packing group 14.5. Environmental hazards 14.6. Special precautions for user 14.7. Transport in bulk according to Annex II of MARPOL73/78 and the IBC Code Most transport information should be obtained from your Dangerous Goods Safety Advisor - [Section 3 of the SDS](https://ttenvironmental.co.uk/clp-knowledgebase/section-3-of-the-sds/) - In the SDS, SECTION 3: Composition/information on ingredients comprises either 3.1. Substances or 3.2. Mixtures Only section 3.1 or section 3.2 is expected, it is the only time when a heading may be legally omitted from the Safety Data Sheet. 3.1 Substances For a substance, you are required to include the product identifiers and the - [Explosives](https://ttenvironmental.co.uk/clp-knowledgebase/explosives/) - Explosives are required to be labelled under CLP, but also have to meet the requirements of the Explosives Regulation, which covers civil explosives. These are governed by the Explosives Regulation 2014, as amended in 2016. For details, see http://www.hse.gov.uk/explosives/regulations2016.htm , which discusses both the 2016 amendment and the 2014 regulation and has links to the regulations and - [Products with dust explosion hazards](https://ttenvironmental.co.uk/clp-knowledgebase/products-with-dust-explosion-hazards/) - Dust explosion hazards are not specifically described under CLP, but do require adding to the Safety Data Sheet. This hazard arises from organic dusts, which may or may not be classified as hazardous under CLP (eg wood flour; wheat flour or grain dust etc). Sometimes the dusts may have Workplace Exposure Limits (WELs), requiring an - [Substances not registered for REACH](https://ttenvironmental.co.uk/clp-knowledgebase/substances-not-registered-for-reach/) - Many substances are made or imported into the UK which do not hold a REACH registration at the time of writing (November 2017), and which are produced in such small quantities that they will never go through REACH registration. In this situation, there will not be REACH registration data available to support a CLP classification - [Products not covered by CLP](https://ttenvironmental.co.uk/clp-knowledgebase/products-not-covered-by-clp/) - There are certain scenarios where CLP is not used because other legislation is in place to describe the hazards. These include: radioactive substances and mixtures (Directive 96/29/Euroatom); (TTE note, also covered by Transport regulations) substances and mixtures which are subject to customs supervision, provided that they do not undergo any treatment or processing, and which - [Acknowledgements](https://ttenvironmental.co.uk/clp-knowledgebase/acknowledgements/) - Dear Knowledgebase subscriber, I would like to acknowledge the help, hard work, questions and suggestions from past and present staff members and contractors, in particular Sandra Hillier-Brook, Janet Readyhough, Julie Bailey and Tom Whitaker. Sincere thanks also go to the many clients and members of the Chemical Regulations Self Help Group who have either been - [Duty of Care in UK Law](https://ttenvironmental.co.uk/clp-knowledgebase/duty-of-care-in-uk-law/) - It might seem a bit strange to be talking about UK law in the context of CLP, which is an over-riding EU regulation which is supposed to supersede national legislation. However, the concept of Duty of Care, which arises from Section 6 of the 1974 Health and Safety at Work Act, affects most, if not - [EUH Statement Classification Forms](https://ttenvironmental.co.uk/clp-knowledgebase/euh-statement-classification-forms/) - You can either use the screening questionnaire for EUH Statements, and then print off the applicable form(s) for your product: Screening questionnaire for EUH Statements EUH Form A Classifying old CHIP hazards by read across EUH Form B Classifying old CHIP hazards from first principles EUH Form C Classifying toxic by eye contact EUH Form - [Specific Concentration Limits](https://ttenvironmental.co.uk/clp-knowledgebase/specific-concentration-limits/) - Specific Concentration Limits (SCLs) are used within CLP where a substance behaves differently in a mixture to that predicted by the normal mixture classification rules. This can be where the effects of the mixture are more severe than calculations would predict, or sometimes where they are less severe. The concept is used in GHS and - [Summary of CLP scope](https://ttenvironmental.co.uk/clp-knowledgebase/summary-of-clp-scope/) - CLP covers some of the main physical, health and environmental hazards for ordinary chemicals, excluding specific products such as foods, pharmaceuticals, wastes etc. Substances and mixtures are included in CLP, and also some articles where a substance or mixture is deliberately released. There are a number of known hazards which are not currently included in - [CLP background summary](https://ttenvironmental.co.uk/clp-knowledgebase/clp-background-summary/) - Hazard communication for chemicals is a very important task, as it is vital in helping people use chemicals safely, and preventing accidents. In the UK, the 1974 Health and Safety at Work Act imposes a duty on everyone to try to ensure that their activities do not affect people at work, or the general public, - [Summary of C&L Notification](https://ttenvironmental.co.uk/clp-knowledgebase/summary-of-c-and-l-notification/) - Notification to the Classification and Labelling (C&L) Inventory is a key part of the CLP regulation, to give a database of what classifications are used throughout the EU for individual substances. C&L Inventory scope includes all hazardous substances (in any quantity), and all REACH-registered non hazardous substances (that is at or above 1 tonne per - [Knowledgebase structure](https://ttenvironmental.co.uk/clp-knowledgebase/structure/) - This is the CLP Knowledgebase structure, all the text contains click-through links to active categories and pages. Categories are listed as headings, and the pages are bullet points. Last updated 10-07-2017. CLP background The importance of hazard communication for chemicals Duty of Care in UK Law Overall sequence of hazard communication What is CLP? Legal - [Section 15 of the SDS](https://ttenvironmental.co.uk/clp-knowledgebase/section-15-of-the-sds/) - In the SDS, SECTION 15: Regulatory information comprises 15.1. Safety, health and environmental regulations/legislation specific for the substance or mixture 15.2. Chemical safety assessment Your Health and Safety professional may be able to assist with this section. 15.1. Safety, health and environmental regulations/legislation specific for the substance or mixture Ozone depleting substance (EC No 2037/2000): (not) - [Persistent Organic Pollutants](https://ttenvironmental.co.uk/clp-knowledgebase/persistent-organic-pollutants/) - Some substances are banned under the EC regulation 850/2004 on persistent organic pollutants (following on from Directive 79/117/EEC), which is brought into UK law via the Persistent Organic Pollutant Regulations, SI 2007 No 3106, see http://www.legislation.gov.uk/uksi/2007/3106/contents . Persistent Organic Pollutants are sometimes referred to as POPs. This is separate to Restriction and Authorisation, although there can be some - [CLP health hazard tests](https://ttenvironmental.co.uk/clp-knowledgebase/clp-health-hazard-tests/) - CLP health hazard tests are the same for both substances and mixtures. Some health hazards are only based on human experience, and very few are covered by Transport. Nearly all health hazard tests are covered by REACH, see 440-2008 Test Method Regulation - 04-03-2016 , and/or by the OECD animal tests, see http://www.oecd-ilibrary.org/environment/oecd-guidelines-for-the-testing-of-chemicals_chem_guide_pkg-en . Most substance testing should - [PBT, Persistent Bioaccumulative and Toxic Substances](https://ttenvironmental.co.uk/clp-knowledgebase/pbt-persistent-bioaccumulative-and-toxic-substances/) - Persistent, bio-accumulative and toxic substances, PBT, is a new type of hazard which was brought into the EU in 2001 , and it has since been brought into the scope of the REACH regulation. The idea is to try to identify materials which are classified as toxic under CLP, and which can build up in animals over - [Is your product a substance or mixture](https://ttenvironmental.co.uk/clp-knowledgebase/is-your-product-a-substance-or-mixture/) - For CLP-classifiable products, the key distinction is whether a product is a substance, or a mixture. This assessment gives you different routes for classification. Substances are defined under CLP, Article 2, Definitions, item 7, as: "a chemical element and its compounds in the natural state or obtained by any manufacturing process, including any additive necessary - [Scope of CLP Harmonised Classifications](https://ttenvironmental.co.uk/clp-knowledgebase/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 - [About the C&L Inventory](https://ttenvironmental.co.uk/clp-knowledgebase/about-the-c-and-l-inventory/) - The Classification and Labelling Inventory (C&L Inventory) is held online at ECHA, and comprises three sets of information: Harmonised classifications (taken from the CLP regulation and its updates) REACH dossier CLP classifications (taken from the disseminated REACH dossiers published by ECHA) CLP classifications notified direct to the C & L Inventory The inventory was set - [How to use the CLP Knowledgebase](https://ttenvironmental.co.uk/clp-knowledgebase/how-to-use-the-clp-knowledgebase/) - The CLP Knowledgebase comprises brief articles on CLP topics, REACH topics to do with Safety Data Sheets, and associated regulations where they touch on CLP and SDS issues. You can either: view all of the categories from the CLP Knowledgebase home page, https://ttenvironmenta.wpengine.com/clp-knowledgebase/, and click through to a category of interest (for reasons of space, we - [CLP Knowledgebase Terms of Use](https://ttenvironmental.co.uk/clp-knowledgebase/clp-knowledgebase-terms-of-use/) - You are supplied with an individual log-in. This must only be used by the named user, either alone or with people viewing the screen with them. Multiple log-ins for users in the same company can be provided for a small extra charge. Log-ins are provided for a year, from the date of the first person - [Summary of selling and advertising hazardous products](https://ttenvironmental.co.uk/clp-knowledgebase/summary-of-selling-and-advertising-hazardous-products/) - There are a number of rules on selling and advertising hazardous products, including: the requirement not to make misleading claims on the label or SDS the requirement to provide information on the hazards of the product prior to sale, particularly for distance selling to consumers There is also an entire regulation, the Prior Informed Consent - [Selling PIC products](https://ttenvironmental.co.uk/clp-knowledgebase/selling-pic-products/) - When selling products which come under the PIC (Prior Informed Consent) Regulation, you must ensure that you comply fully with all requirements of this regulation, particularly around export. For details, see ECHA's Guidance on PIC, https://echa.europa.eu/documents/10162/23036412/guidance_pic_en.pdf/813e3826-5b6d-4a31-9088-6bb9ceae34b4 . Penalties for non-compliance can be severe. - [Selling and advertising products with a Safety Data Sheet](https://ttenvironmental.co.uk/clp-knowledgebase/selling-and-advertising-products-with-a-safety-data-sheet/) - Every product which is classified for CLP requires a Safety Data Sheet, unless it is being sold to consumers. Even where consumers are being supplied, if a professional user were to buy the product, they may still ask for a Safety Data Sheet (SDS) if they need one e.g. for their own risk assessments. However, - [Non hazardous products](https://ttenvironmental.co.uk/clp-knowledgebase/non-hazardous-products/) - Strictly speaking, "non hazardous" is a term which is avoided in CLP and GHS, and the correct term is "non classified", but this section is about products which are not classified, and which don't have any other hazard communication requirements. There are two potential types of "non hazardous product": non classified for CLP, but require - [Authorised Substances](https://ttenvironmental.co.uk/clp-knowledgebase/authorised-substances/) - Authorised substances are those listed in Annex XIII of REACH, which are in the process of being removed from the EU market. For more details, see https://ttenvironmenta.wpengine.com/clp-knowledgebase/authorisation-list/ . Authorised substance –placing on the market If you are selling or reselling an Authorised substance, where on its own or in a mixture, you will need to: make - [Articles containing CLP products](https://ttenvironmental.co.uk/clp-knowledgebase/articles-containing-clp-products/) - Substances and mixtures in articles can be present in four main ways: designed to be released from an article, e.g. from a wet wipe, or sponge, or ink from a pen sealed in the article, and only released in an accident, e.g. acid in a battery incorporated into the physical matrix of an article, and - [SVHCs on candidate list](https://ttenvironmental.co.uk/clp-knowledgebase/svhcs-on-candidate-list/) - A substance which is an SVHC on candidate list, but which is not Authorised triggers certain obligations for hazard communication. SVHCs on candidate list - placing substance or mixture on the market An SVHC substance, or a substance with SVHC impurity, or mixture containing SVHC component: even if not classified for CLP, still requires SDS - [Substances with uses not registered under REACH](https://ttenvironmental.co.uk/clp-knowledgebase/substances-with-uses-not-registered-under-reach/) - REACH involved the registration of uses for each substance, as well as the registration of the substance itself. This means that sometimes, for hazardous products, certain uses are not registered. Also, as information comes to light through the REACH process, it becomes apparent that certain uses would expose people to dangerous levels of a substance, - [Stabilised products](https://ttenvironmental.co.uk/clp-knowledgebase/stabilised-products/) - Substances or mixtures can be stabilised for several reasons: to prevent polymerisation and exotherm leading to explosion or fire (e.g. liquid monomers) to prevent oxidation leading to fire (e.g. self-heating or self-reactive powders) to preserve the product shelf life (e.g. biocidal preservatives in an organic solution which would otherwise bio-degrade) Stabilisers can therefore affect the - [Sensitiser containing products](https://ttenvironmental.co.uk/clp-knowledgebase/sensitisers-containing-products/) - Products may contain sensitisers where they are present at concentrations triggering: the formal CLP/GHS classification(s) of Skin Sens 1, H317, and/or Resp Sens 1, H334 apply; formal CLP/GHS classification and reporting level for EUH208 reporting on the label at EUH208 only Note that where EUH208 applies and there is no other classification, EUH210 also applies - [Products with Workplace Exposure Limits](https://ttenvironmental.co.uk/clp-knowledgebase/products-with-workplace-exposure-limits/) - Workplace Exposure Limits are provided to ensure that workers are not exposed to high levels of hazardous substances which might adversely affect their health. For more details, see https://ttenvironmenta.wpengine.com/clp-knowledgebase/chemicals-with-workplace-exposure-limits/ . Products with Workplace Exposure Limits – placing on the market Substances or mixtures which hold Workplace Exposure Limits, WELs, may either be classified as hazardous under - [Products with a Harmonised Classification](https://ttenvironmental.co.uk/clp-knowledgebase/products-with-a-harmonised-classification/) - Products which have a Harmonised Classification under CLP should generally be considered to have a Partial Harmonised Classification, unless they are a pesticide or biocide, when all hazards are required to be included in the classification. This means that you have to check for yourself whether any other hazards need identifying. Once you have a full - [Product samples](https://ttenvironmental.co.uk/clp-knowledgebase/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 - [Pesticides, including plant protection products](https://ttenvironmental.co.uk/clp-knowledgebase/pesticides-including-plant-protection-products/) - Pesticide regulations in the UK covers all types of products used to kill unwanted insects, plants and animals, and includes: plant protection products (specific agricultural, horticultural and amenity land insecticides, herbicides, acaricides etc) other pesticides such as insecticides, rodenticides etc Plant Protection Products are required to have specific labelling as well as CLP information on - [Chromic acid solutions](https://ttenvironmental.co.uk/clp-knowledgebase/chromic-acid-solutions/) - The classification of chromic acid solutions has been under debate in the UK and EU for some time. This is of particular concern to companies in the surface treatment industry, who use it as part of electroplating processes, as the CLP classification impacts on the COMAH classification. Briefly, although chromic acid solutions can be made - [Candles](https://ttenvironmental.co.uk/clp-knowledgebase/candles/) - Candles were not considered to be classifiable under CHIP, but this situation has changed under CLP, where they are considered as being mixtures (even though they are not liquids). Candles containing hazardous components such as dyes or fragrances are considered to be potentially hazardous to health, and require classification like any other hazardous product. The - [Bulk chemicals](https://ttenvironmental.co.uk/clp-knowledgebase/bulk-chemicals/) - Bulk chemicals are defined as those chemicals which are stored in tanks, and moved by pipeline, or using bulk tanker. Bulk chemicals are not labelled for CLP for transport, as only Transport labelling is required on a bulk tanker. However, it is likely that a Safety Data Sheet will be required for the product under - [Biocides](https://ttenvironmental.co.uk/clp-knowledgebase/biocides/) - Biocides need to comply with CLP, and also with the Biocidal Product Regulation from the EU. As well as having BPR information on the product label, there is the requirement to only use approved biocides in your biocidal products, and also to register your biocidal products. This means that there are two separate registration duties - [Asbestos containing articles](https://ttenvironmental.co.uk/clp-knowledgebase/asbestos-containing-articles/) - Articles containing Asbestos are regulated under REACH, Appendix 7, and an extract is attached for reference Appendix VII extracted from Consolidated REACH regs 11-10-2016. This requires all articles containing Asbestos to be labelled with extra information showing that the article contains asbestos, which can be directly printed on the article, or affixed as a label. This - [Aerosols](https://ttenvironmental.co.uk/clp-knowledgebase/aerosols/) - Aerosols have a specific set of rules for classification, and also additional requirements for labelling. The definition of aerosols in CLP is "aerosol dispensers are any non-refillable receptacles made of metal, glass or plastics and containing a gas compressed, liquefied or dissolved under pressure, with or without a liquid, paste or powder, and fitted with - [Overall sequence of hazard communication](https://ttenvironmental.co.uk/clp-knowledgebase/overall-sequence-of-hazard-communication/) - There is an overall sequence to communicating the hazards of chemicals. First, you need to classify the chemical (which under CLP means classifying for CLP-GHS hazards, and then classifying for EUH hazards); then produce labelling information; and finally write the Safety Data Sheet (SDS), although SDSs are not necessarily required for consumer products. There may - [List of Poison Centres](https://ttenvironmental.co.uk/clp-knowledgebase/list-of-poison-centres/) - ECHA provide a list of Poison Centres, which can be downloaded here: Poison Centres List 2014 from ECHA . There is further information on the Poison Centre website at https://poisoncentres.echa.europa.eu/ . - [Summary of Poison Centre Notification](https://ttenvironmental.co.uk/clp-knowledgebase/summary-of-poison-centre-notification/) - Poison Centre Notification has been around since 1999 under the Dangerous Preparations Directive, when notification of hazardous mixtures to Poison Centres in individual countries of the EU was first brought in. The system enables users of hazardous mixtures to contact the Poison Centre in an emergency, and receive appropriate advice, particularly for medical treatment. This - [About Poison Centre Notification](https://ttenvironmental.co.uk/clp-knowledgebase/about-poison-centre-notification/) - CLP Article 45 provides for each Member State of the EU to appoint bodies responsible to hold information on hazardous mixtures imported or made in the EU, for the purposes of providing a central contact point in an emergency for users such as medical professionals and/or the general public. This continues the process started under - [Generating a UFI](https://ttenvironmental.co.uk/clp-knowledgebase/generating-a-ufi/) - It is up to the supplier of a product, that is the Importer or Formulator, to generate a Unique Formulation Identifier for that product. Anyone reselling the product should use the same UFI (assuming the mixture has not been altered in any way). The UFI number format is a mixture of alphabetical and numerical figures in - [Unique Formulation Identifier number](https://ttenvironmental.co.uk/clp-knowledgebase/unique-formulation-identifier-number/) - The Unique Formulation Identifier number, or UFI, is a number to identify a formulation or mixture in a way analogous to the CAS or EC number, but only for mixtures sold within the EU. The UFI does not replace any hazardous substance identity numbers, as these will still be required to be included in the - [Scope of Poison Centre Notification](https://ttenvironmental.co.uk/clp-knowledgebase/scope-of-poison-centre-notification/) - Mixtures required to be notified to Poison Centres Poison Centre Notification is only required for mixtures, and is not required for substances. The exact definition is: "mixtures classified as hazardous on the basis of their health or physical effects". It is not clear whether this definition refers only to CLP-GHS hazards, or whether is includes - [About SDS Sections](https://ttenvironmental.co.uk/clp-knowledgebase/about-sds-sections/) - This part of the Knowledgbase goes through the 16 SDS sections, plus the SDS Annex, individually with information and guidance on what should go into each part. An SDS with basic guidance which summarises the information in this section has also been provided here: SDS with basic guidance v1.1 07-07-2017 . If you are in doubt - [SDS Annex](https://ttenvironmental.co.uk/clp-knowledgebase/sds-annex/) - The Annex to the SDS is currently only required for substances which have been registered under REACH at 10 tonnes per annum or above, including where a use has been registered separately from the main registration, where a Chemical Safety Report has been produced. ECHA provide a free software tool, CHESAR, to help you write - [Section 12 of the SDS](https://ttenvironmental.co.uk/clp-knowledgebase/section-12-of-the-sds/) - In the SDS, SECTION 12: Ecological information comprises: 12.1. Toxicity 12.2. Persistence and degradability 12.3. Bioaccumulative potential 12.4. Mobility in soil 12.5. Results of PBT and vPvB assessment 12.6. Other adverse effects This section usually includes the following information on substances, which should be the data underpinning the classification for each of these hazards. If you - [Section 11 of the SDS](https://ttenvironmental.co.uk/clp-knowledgebase/section-11-of-the-sds/) - In the SDS, SECTION 11: Toxicological information comprises: 11.1. Information on toxicological effects 11.2 Other information 11.1. Information on toxicological effects This section usually includes the following information on substances, which should be the data underpinning the classification for each of these hazards. If you have registered the substance for REACH, the data in this section must - [Section 4 of the SDS](https://ttenvironmental.co.uk/clp-knowledgebase/section-4-of-the-sds/) - In the SDS, SECTION 4: First aid measures comprises 4.1. Description of first aid measures 4.2. Most important symptoms and effects, both acute and delayed 4.3. Indication of any immediate medical attention and special treatment needed If you are not a qualified first aider, you may find this section daunting to complete, particularly for high-hazard products. - [Section 2 of the SDS](https://ttenvironmental.co.uk/clp-knowledgebase/section-2-of-the-sds/) - In the SDS, SECTION 2: Hazards identification comprises: 2.1. Classification of the substance or mixture 2.2. Label elements 2.3. Other hazards 2.1 Classification of the substance or mixture The CLP classification of both substances and mixtures is required here. This should include the hazard class (the type of hazard, e.g. flammable liquid and vapour, or acute - [Mixture components identified on SDS](https://ttenvironmental.co.uk/clp-knowledgebase/mixture-components-identified-on-sds/) - Substances contained in mixtures classified for CLP are required to be identified on the SDS under Section 3.2: If the mixture is classified for CLP, its component substances must be identified if they meet one or more of the following criteria, and if more than one criterion applies the lowest limit must be used: substance is - [Specific REACH information on the SDS](https://ttenvironmental.co.uk/clp-knowledgebase/specific-reach-information-on-the-sds/) - The overall Safety Data Sheet (SDS) framework is defined within GHS, and is currently brought into EU law via the REACH regulations. This might be seen as an unusual approach, as GHS itself contains information on classification, labelling, packaging and the SDS, as CHIP did prior to REACH being implemented in 2008. The reason why - [Issuing Safety Data Sheets to users](https://ttenvironmental.co.uk/clp-knowledgebase/issuing-safety-data-sheets-to-users/) - Where a product requires a Safety Data Sheet (SDS), one must be issued to the purchaser or user on or before the date of first supply. Note that SDSs are not required for consumer products, those sold to the general public. SDSs must be supplied in the language of the user, and they must be - [About CHIP](https://ttenvironmental.co.uk/clp-knowledgebase/about-chip/) - CHIP stands for The Chemicals (Hazard Information and Packaging for Supply) Regulations. It was the UK regulation used for classifying, labelling, and packaging chemicals for supply prior to CLP being introduced. It was based on the Dangerous Substances Directive and Dangerous Preparations Directive from the EU, covering substances and mixtures (or formulations, or preparations) respectively. CHIP originally - [Converting CHIP classifications to CLP](https://ttenvironmental.co.uk/clp-knowledgebase/converting-chip-classifications-to-clp/) - There are two ways to classify a substance or mixture for CLP using CHIP information: classify on the basis of data available in a CHIP Safety Data Sheet (SDS) convert the CHIP classification into a CLP classification using the Annex VII method The first method involves classifying from first principles on the basis of data, using - [CAS numbers](https://ttenvironmental.co.uk/clp-knowledgebase/cas-numbers/) - CAS numbers are used to identify specific chemical substances, and are valid for identifying chemical substances in CLP and on the Safety Data Sheet. CAS numbers are the main chemical identification used by the chemical industry worldwide. CAS number (or CAS registry number), refers to the Chemicals Abstract Service number. This is run by the American - [Safety Data Sheet writing sequence](https://ttenvironmental.co.uk/clp-knowledgebase/safety-data-sheet-writing-sequence/) - The sequence for writing Safety Data Sheets (SDSs) is as follows: Obtain full CLP classification, any EUH hazards, and labelling information for the substance or mixture, https://ttenvironmenta.wpengine.com/clp-knowledgebase/the-clp-classification-sequence/ , https://ttenvironmenta.wpengine.com/knowledgebase_category/euh-statement-classification/ and https://ttenvironmenta.wpengine.com/clp-knowledgebase/clp-labelling-sequence/ If the product is not classified for CLP, check whether an SDS is required for other reasons, e.g. contains an SVHC, holds a Workplace Exposure Limit etc, - [Summary of CLP labelling](https://ttenvironmental.co.uk/clp-knowledgebase/summary-of-clp-labelling/) - Information for the CLP label is based on: the Product Identifiers (substance name and identifying number(s); or trade name of mixture, and "contains xxx", for component substances with health hazards) the CLP-GHS classification, which is used to generate the pictogram(s), Signal Word, and P Statements required for the label the EUH statement classification, which gives - [Individual CLP pictogram labels](https://ttenvironmental.co.uk/clp-knowledgebase/individual-clp-pictogram-labels/) - Some label companies are offering individual CLP pictograms (or symbols), that is the diamonds with the red border, white background and black hazard symbol, as individual labels for sale. Strictly speaking, this is not allowable under CLP, as all of the CLP information should be placed on the label. This may be due to confusion - [Tactile CLP Labels](https://ttenvironmental.co.uk/clp-knowledgebase/tactile-clp-labels/) - Tactile CLP labels or packages are required for consumer products with specific hazards. The tactile warning sign for chemical hazards is a raised triangle. This can either be transparent, to allow information beneath the label to be read, or it can be opaque. These are: Acute toxicity Category 1 to 3: H300, H310, H330, H301, - [Fixing the CLP Label to a Package](https://ttenvironmental.co.uk/clp-knowledgebase/fixing-the-clp-label-to-a-package/) - CLP contains some rules about where a CLP label should be fixed to a package. Briefly, the label should be readable when the package is being stored. For drums and IBCs, this means the label should be on the side of the drum, not the top. For sacks, this means the label should be positioned depending on - [CLP Label Printing](https://ttenvironmental.co.uk/clp-knowledgebase/clp-label-printing/) - A CLP label can either be printed directly onto a package, or onto a label, although most CLP labels are printed onto a label which is then fixed onto the package. CLP does not specify any details for the type of label paper to be used (the "substrate"), and no requirement is given on the - [Unique Formulation Identifier](https://ttenvironmental.co.uk/clp-knowledgebase/unique-formulation-identifier/) - The Unique Formulation Identifier is going to be required for mixtures sold within the EU. The UFI is generated when a mixture is registered with an individual Poison Centre, and is then valid across the EU. There is a phase in period as follows: consumer use, 2020 professional use, 2021 industrial use, 2024 The situation - [About CLP Labelling](https://ttenvironmental.co.uk/clp-knowledgebase/about-clp-labelling/) - The CLP labelling sequence is: obtain the CLP-GHS classification, either from published sources (Harmonised Classification, REACH registration classification, or Classification and Labelling Inventory entry), or from self-classification (see https://ttenvironmenta.wpengine.com/clp-knowledgebase/the-clp-classification-sequence/ ) classify the product for EUH Statements, see: https://ttenvironmenta.wpengine.com/knowledgebase_category/euh-statement-classification/ check to see how many labels are required, and what size of package(s) need to be labelled: https://ttenvironmenta.wpengine.com/clp-knowledgebase/packages-requiring-clp-labels/ generate - [Flammability of liquid mixtures calculation](https://ttenvironmental.co.uk/clp-knowledgebase/flammability-of-liquid-mixtures-calculation/) - The flammability of liquid mixtures is based on an assessment of the flash point and the initial boiling point. Both of these can be tested, but it is also possible to calculate the flash point of a liquid mixture. Calculating the flash point of liquid mixtures There is more than one acceptable method for calculating - [Bridging principles and read-across for mixture classification](https://ttenvironmental.co.uk/clp-knowledgebase/bridging-principles-and-read-across-for-mixture-classification/) - Where you do not have published test data on a mixture for health or environmental hazards, it is sometimes possible to compare the substance with similar mixtures which have been tested. CLP includes "bridging principles" in section 1.1.3, which lay out the exact circumstances when you can use test data from a similar mixture, which cover: dilution or - [Obtaining a mixture recipe for CLP classification](https://ttenvironmental.co.uk/clp-knowledgebase/obtaining-a-mixture-recipe-for-clp-classification/) - It is not unusual to find that you do not have some or all of the mixture information you need to be able to classify it for CLP. There are several situations where this may occur when you are importing a mixture from outside the EU: the SDS does not include any recipe because the format of - [Summary of the CLP classification process](https://ttenvironmental.co.uk/clp-knowledgebase/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 - [Procedure for classifying mixtures](https://ttenvironmental.co.uk/clp-knowledgebase/procedure-for-classifying-mixtures/) - There is a single procedure for classifying mixtures, although it does split into two parts, one for physical hazards and another for health and environmental hazards. If you have test data available for the mixture, classify from first principles. Test data on existing mixtures is usually found in non-CLP Safety Data Sheets, see https://ttenvironmenta.wpengine.com/clp-knowledgebase/using-data-from-non-clp-safety-data-sheets/ . If you - [About classifying for EUH hazards](https://ttenvironmental.co.uk/clp-knowledgebase/about-classifying-for-euh-hazards/) - EUH Statements are not part of the CLP-GHS classification, but additional labelling information used in the EU. Extra label information is permitted under GHS, so this does not breach the GHS standard. EUH Statements can apply to both substances and mixtures. There are four types of EUH Statement: old CHIP classifications (R phrases) health hazards - [Summary of EUH Statement classification](https://ttenvironmental.co.uk/clp-knowledgebase/summary-of-euh-statement-classification/) - EUH Statements are not part of the CLP-GHS classification, but additional labelling information used in the EU. They should be classified after the CLP-GHS classification has been obtained, as some are at a lower level and can be superseded by the CLP-GHS classification. EUH Statements can be classified in several ways, depending on what type - [Detergents](https://ttenvironmental.co.uk/clp-knowledgebase/detergents/) - Detergents, that is cleaning products containing surfactants or soaps, are regulated according to the Detergents Regulation (2010) in the UK, as well as CLP. This may mean that different disclosure thresholds apply to specific ingredients in detergents, compared to if they were CLP-only products. Other labelling elements may also apply. Information on these legal requirements - [CLP environmental hazard tests](https://ttenvironmental.co.uk/clp-knowledgebase/clp-environmental-hazard-tests/) - Environmental tests are the same for both substances and mixtures. All environmental hazard tests (and more which are not included under CLP) are covered by REACH, see 440-2008 Test Method Regulation – 04-03-2016 , and/or by the OECD animal tests, see http://www.oecd-ilibrary.org/environment/oecd-guidelines-for-the-testing-of-chemicals_chem_guide_pkg-en . You should only need to carry out environmental hazard tests on substances which are not registered for REACH, - [Summary of tests for CLP classification](https://ttenvironmental.co.uk/clp-knowledgebase/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 - [Modelling and read-across for substance classification](https://ttenvironmental.co.uk/clp-knowledgebase/modelling-and-read-across-for-substance-classification/) - Modelling and read-across for predicting the physical hazards of substances is not appropriate, as there are no barriers to testing, and if a hazard is possible, then it should be tested for. Where you do not have published test data on a substance for health or environmental hazards, it is sometimes possible to compare the - [Summary of published non CLP classifications](https://ttenvironmental.co.uk/clp-knowledgebase/summary-of-published-non-clp-classifications/) - It is possible to convert some non-CLP classifications to CLP relatively easily, using read-across methods, including: GHS classifications from other jurisdictions CHIP classifications Transport classifications For CHIP-classified products, a combination of the Annex VII read-across method with the Transport classification read-across method may be useful. The NFPA 704 diamond label may also provide useful information - [Using NFPA ratings for CLP](https://ttenvironmental.co.uk/clp-knowledgebase/using-nfpa-ratings-for-clp/) - The NFPA (National Fire Protection Authority) rating is used in the USA to provide advice on hazardous materials to emergency responders. It is a label comprising a diamond containing 4 smaller diamonds, covering (from the left, moving clockwise): blue diamond - health hazard red diamond - fire hazard yellow diamond - reactivity hazard white diamond - [CLP classifications on supplier SDSs](https://ttenvironmental.co.uk/clp-knowledgebase/clp-classifications-on-supplier-sdss/) - Supplier Safety Data Sheets (SDSs), or SDSs from reputable third-parties such as large chemical suppliers, can contain useful information for classifying substances, particularly information on component substances needed for a mixture classification. All CLP and GHS classification information should be placed on a GHS-compliant SDS, which means the classification sits in Section 2.1 of the - [About published CLP classifications](https://ttenvironmental.co.uk/clp-knowledgebase/about-published-clp-classifications/) - Published CLP substance classifications There are several reasons for using published CLP substance classifications: If you are reselling a substance from within the EU, you should use the CLP classification information provided by your supplier. If you make or import a substance with a Harmonised Classification, you must classify the harmonised hazards in accordance with - [Keeping CLP and SDS information on file](https://ttenvironmental.co.uk/clp-knowledgebase/keeping-clp-and-sds-information-on-file/) - Under CLP and REACH, you are required to keep all of the information relating to a classification, label or SDS for 10 years from the date of last supply of the product. This means that you need to keep all of the information relating to the classification of the product which has been used in - [Using existing information when classifying for CLP](https://ttenvironmental.co.uk/clp-knowledgebase/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 - [Who is responsible for classifying and labelling a product](https://ttenvironmental.co.uk/clp-knowledgebase/who-is-responsible-for-classifying-and-labelling-a-product/) - The person or company who places a product on the market is responsible for its classification and labelling (and for producing the SDS, if one is required). Although liability initially rests with the manufacturer or importer, it is passed to the company who resells it. For example, Company A makes a surfactant, and sells it - [About selling and advertising hazardous products](https://ttenvironmental.co.uk/clp-knowledgebase/about-selling-and-advertising-hazardous-products/) - There are various rules related to selling and advertising hazardous products, depending on whether you are selling to the general public, professionals, or industry; and whether the sale is made face-to-face, or over the internet, and these rules come under both CLP and REACH (with regard to safety data sheets). In the UK, breaches can - [Summary of chemicals with non-CLP designations](https://ttenvironmental.co.uk/clp-knowledgebase/summary-of-chemicals-with-non-clp-designations/) - Some non-CLP designations can affect the CLP label, and/or the Safety Data Sheet (SDS). These designations include: Chemicals on the SVHC Candidate List Authorised substances Restricted substances Chemicals with Workplace Exposure Substance Limits PBT and vPvB substances Ozone depleting substances are important to CLP as they give rise to the classification Hazardous to the Ozone Layer, - [Ozone depleting chemicals](https://ttenvironmental.co.uk/clp-knowledgebase/ozone-depleting-chemicals/) - Ozone depleting chemicals are regulated internationally under the Montreal Protocol, see http://ozone.unep.org/en/treaties-and-decisions/montreal-protocol-substances-deplete-ozone-layer. Some ozone depleting substances (ODSs) have already been phased out completely, and the use of others is being discouraged. However, although many ozone depleting substances are used as refrigerant gases, where substitution may be possible, others may also be used as pesticides, or - [About chemicals with non-CLP designations](https://ttenvironmental.co.uk/clp-knowledgebase/about-chemicals-with-non-clp-designations/) - Some chemicals have been assigned non-CLP designations which may still affect the CLP label, and also the Safety Data Sheet (SDS). Most of these non-CLP designations derive from the REACH regulation, and one is derived by the EU and individual member states (chemicals with occupational exposure limits). Nano materials have been included because they are - [Summary of chemical identification](https://ttenvironmental.co.uk/clp-knowledgebase/summary-of-chemical-identification/) - The purpose of chemical identification within CLP is to ensure that each substance is clearly and unambiguously identified, and that all mixtures are identified, together with its hazardous component substances. All of the hazardous components in a mixture must be identified on the Safety Data Sheet (SDS), but not all need to be identified on - [About chemical identification in CLP](https://ttenvironmental.co.uk/clp-knowledgebase/about-chemical-identification-in-clp/) - Chemicals are identified in two ways in CLP, depending on whether they are substances or mixtures. The overall principles of chemical identification within CLP are to make sure that a substance is correctly and unambiguously identified, that a mixture is correctly and unambiguously identified, and that component substances in mixtures are correctly identified. This is so - [Chemical trade names](https://ttenvironmental.co.uk/clp-knowledgebase/chemical-trade-names/) - Chemical trade names, for both substances and mixtures, have been used for decades by the chemical industry. There have been numerous changes of trade name as companies have change hands and rationalised their product lists, or altered the trade name to one which matches their own style. If you are using a substance with a - [The chemical formula](https://ttenvironmental.co.uk/clp-knowledgebase/the-chemical-formula/) - The chemical formula is a shorthand way of showing the constituents of a substance. The chemical formula is not required for CLP classification, but is required for Classification and Labelling Inventory notification, and REACH registration. It can also be listed on the Safety Data Sheet for a substance. The formula comprises the element symbol from - [Summary of CLP Building Blocks](https://ttenvironmental.co.uk/clp-knowledgebase/summary-of-clp-building-blocks/) - CLP is based on a number of building blocks, many of which come directly from GHS, with a few items from CHIP. Items derived from GHS include: specific substance and mixture identifiers CLP-GHS classifications Signal Word Pictograms Hazard Statements P Statements the concept of Multiplication factors (M-factors) for aquatic toxins which are more hazardous than - [M-factors](https://ttenvironmental.co.uk/clp-knowledgebase/m-factors/) - The M-factor is a Multiplication-factor which can be applied to substances with aquatic toxicity which have a more severe impact in mixtures than the generic classifications would suggest. The concept originates in GHS and has been adopted in CLP. As its name implies, the M-factor is a factor, or number. It is applied by multiplying the - [Harmonised Classifications under CLP](https://ttenvironmental.co.uk/clp-knowledgebase/harmonised-classifications-under-clp/) - The GHS standard does not contain any mandatory chemical classifications, unlike the Transport system which uses the Dangerous Goods List as the starting point for classification. This means that individual jurisdictions are free to classify chemicals how they like (within reason), and there can be significant differences in mandatory classifications for supply between countries. The - [Labelling forms](https://ttenvironmental.co.uk/clp-knowledgebase/labelling-forms/) - Label information forms There are eight possible label information forms to use, depending on whether the product is a substance or a mixture; whether it is used industrially (or professionally), or by consumers; and whether it is a normal size pack, or less than 3 litres pack. Substance for industrial/ professional use: Label information form - [About CLP Building Blocks](https://ttenvironmental.co.uk/clp-knowledgebase/about-clp-building-blocks/) - Most chemical classification systems have very similar elements, and CLP contains similar elements to CHIP, its precursor. Specific rules for product identification, see https://ttenvironmenta.wpengine.com/clp-knowledgebase/product-identifiers/ Classification categories for different hazard types - CLP-GHS classifications, see https://ttenvironmenta.wpengine.com/clp-knowledgebase/clp-ghs-classifications/ Symbol showing hazards - Pictograms in CLP/GHS, see https://ttenvironmenta.wpengine.com/clp-knowledgebase/clp-pictograms-symbols/ Written summary of hazards - Signal Word in CLP/GHS, see https://ttenvironmenta.wpengine.com/clp-knowledgebase/the-signal-word/ Detailed written description of hazards - [Overall scope of CLP](https://ttenvironmental.co.uk/clp-knowledgebase/overall-scope-of-clp/) - GHS, and therefore CLP, applies to: substances (pure, and with impurities affecting their classification) substances in dilute solution mixtures GHS, and CLP, does not generally apply to articles, except explosive articles and articles producing a pyrotechnic effect. CLP only applies to chemicals used for general purposes. Chemicals used specifically as medicines, cosmetics, food, veterinary medicines - [About Transport of Dangerous Goods](https://ttenvironmental.co.uk/clp-knowledgebase/about-transport-of-dangerous-goods/) - The UN runs the systems for the Transport of Dangerous Goods, which cover a variety of modes (types of transport). In Europe, road is covered by ADR (via the Orange Book); IMDG covers sea transport; IATA covers air transport; and ADN covers inland waterways such as rivers, lakes and canals. Rail is covered by Appendix - [CHIP within CLP](https://ttenvironmental.co.uk/clp-knowledgebase/chip-within-clp/) - CLP has brought across parts of CHIP to cover areas where the EU think that GHS is not suitable for the EU. The main CHIP parts of CLP are: the list of Harmonised Classifications in Table 3.1 of Annex VI to CLP, which is based on the old Approved Supply List held within CHIP, but - [The importance of hazard communication for chemicals](https://ttenvironmental.co.uk/clp-knowledgebase/the-importance-of-hazard-communication-for-chemicals/) - In the chemical industry, it is easy to take hazard communication for chemicals for granted. We are so used to seeing correctly labelled packages, and receiving Safety Data Sheets for every chemical we use, whether hazardous or not, that we can become a bit "blind" to their importance. The further away from the chemical manufacturer - [Restricted substances](https://ttenvironmental.co.uk/clp-knowledgebase/restricted-substances/) - Substances are restricted under Annex XVII of REACH. Restriction means that they are not allowed to be used for certain uses, or by certain groups (eg no consumers). For further details, see https://ttenvironmenta.wpengine.com/clp-knowledgebase/restricted-chemicals/ . Restricted substances – placing on the market Where you are placing a restricted substance on the market, you are required to: abide - [Biological hazards](https://ttenvironmental.co.uk/clp-knowledgebase/biological-hazards/) - Biological hazards are not covered specifically within CLP, although a material with biohazards may also be classifiable for CLP. However, Transport does cover biological hazards, so transport labelling must reflect this. - [Products with labelling derogations](https://ttenvironmental.co.uk/clp-knowledgebase/products-with-labelling-derogations/) - Certain products are allowed to have reduced label information or no CLP labels. These derogations are listed in the CLP Regulation, Annex I, section 1.2, Derogations from labelling requirements for special cases and include: transportable gas cylinders (with a water capacity 150 litres or less) gas containers intended for propane, butane or liquefied petroleum gas - [Packaging Laundry Liquitabs](https://ttenvironmental.co.uk/clp-knowledgebase/packaging-laundry-liquitabs/) - CLP imposes extra duties on companies supplying laundry liquitabs for consumer use. Liquitabs are the brightly coloured soluble packages used for laundry detergent, which can look like they might be sweets, especially to a small child. In Part 3 of Annex II to Regulation (EC) No 1272/2008 the following section 3.3 is added: ‘3.3 Liquid - [Laundry Liquitabs](https://ttenvironmental.co.uk/clp-knowledgebase/laundry-liquitabs/) - Laundry liquitabs, that is coloured liquid laundry detergents in soluble packaging, have been found to be highly attractive to very small children, and there have been several incidents inside the EU where babies and toddlers have chewed through the packaging and caused themselves harm. To try to reduce the risks, the EC issued an update - [Small packages](https://ttenvironmental.co.uk/clp-knowledgebase/small-packages/) - The rules on small packages only affect the label type and size, and sometimes the label information required. The same rules on SDSs apply, regardless of the size of the package. Where a label is so small that information can be omitted, this does not apply to outer packages containing multiple small packages, where a - [Ask a question](https://ttenvironmental.co.uk/clp-knowledgebase/ask-a-question/) - As a registered CLP Knowledgebase user, you can ask TT Environmental a question, and if it is pertinent to the Knowledgebase, we will answer it, and update the Knowledgebase accordingly. We also like to hear of any mistakes or typographical errors, or differences in interpretation of the various regulations discussed in the Knowledgebase. To ask - [Finding information on component substances](https://ttenvironmental.co.uk/clp-knowledgebase/finding-information-on-component-substances/) - In order to classify a mixture for health and environmental hazards, it is essential to know the CLP classification of every component substance. However, this information may only be available with CHIP classifications, or other non-CLP/GHS classifications (e.g. from an old SDS, or a non-GHS jurisdiction); or GHS rather than CLP classifications, from outside the - [Summary of SDSs](https://ttenvironmental.co.uk/clp-knowledgebase/summary-of-sdss/) - SDSs are required by law for industrial and professional users for both substances and mixtures which are classified for CLP, or have EUH statements, or hold WELs. They may also be produced voluntarily for products which do not require an SDS but require information to be communicated down the supply chain (as listed in Article - [SDS competent person](https://ttenvironmental.co.uk/clp-knowledgebase/sds-competent-person/) - SDSs must be compiled by a “competent person”. This is not defined in REACH, but there is guidance in ECHA SDS document section 2.5. The authors of the ECHA guidance recognise that an SDS may require input from different specialists, e.g. a regulatory affairs person to classify a product; an occupational Health and Safety person, - [Section 16 of the SDS](https://ttenvironmental.co.uk/clp-knowledgebase/section-16-of-the-sds/) - In the SDS, SECTION 16: Other information comprises: Changes made to SDS: Either new SDS, not applicable, or SDS version number, revision number, and section x – changes/ section y/ changes. Key (or legend) Include any abbreviations or acronyms used in SDS Literature references list sources of data, published or unpublished Details of relevant hazard information - [Section 13 of the SDS](https://ttenvironmental.co.uk/clp-knowledgebase/section-13-of-the-sds/) - In the SDS, SECTION 13: Disposal considerations comprises 13.1. Waste treatment methods As well as consulting a trained chemist (if you are not one yourself), your Health and Safety professional may have information on waste, alternatively if you use a chemical waste disposal company, they may be able to provide advice for this section. 13.1. Waste - [Section 9 of the SDS](https://ttenvironmental.co.uk/clp-knowledgebase/section-9-of-the-sds/) - In the SDS, SECTION 9: Physical and chemical properties comprises: 9.1. Information on basic physical and chemical properties 9.2. Other information Some of this information may be inferred from the CLP classification, and other parts will need to be obtained from testing. Published information on the ECHA website (C&L inventory, and the REACH dossiers), and also - [Section 10 of the SDS](https://ttenvironmental.co.uk/clp-knowledgebase/section-10-of-the-sds/) - In the SDS, SECTION 10: Stability and reactivity comprises: 10.1. Reactivity 10.2. Chemical stability 10.3. Possibility of hazardous reactions 10.4. Conditions to avoid 10.5. Incompatible materials 10.6. Hazardous decomposition products 10.1. Reactivity Either “not applicable” or give details e.g. reacts with xxx, or family of yyyy, brief details of specific test data if available. As mentioned - [Section 7 of the SDS](https://ttenvironmental.co.uk/clp-knowledgebase/section-7-of-the-sds/) - In the SDS, SECTION 7: Handling and storage comprises: 7.1. Precautions for safe handling 7.2. Conditions for safe storage, including any incompatibilities 7.3. Specific end use(s) It can be helpful to discuss this section with your site's Health and Safety professional, and/or a trained chemist. It may be possible to use existing P statements to provide - [Section 6 of the SDS](https://ttenvironmental.co.uk/clp-knowledgebase/section-6-of-the-sds/) - In the SDS, SECTION 6: Accidental release measures comprises: 6.1. Personal precautions, protective equipment and emergency procedures 6.2. Environmental precautions 6.3. Methods and material for containment and cleaning up 6.4. Reference to other sections This section can also be tricky to get right, as the consequences of giving advice could be very serious. It can be - [Section 5 of the SDS](https://ttenvironmental.co.uk/clp-knowledgebase/section-5-of-the-sds/) - In the SDS, SECTION 5: Firefighting measures comprises 5.1. Extinguishing media 5.2. Special hazards arising from the substance or mixture 5.3. Advice for firefighters Like the section on first aid, this section can appear daunting to anyone who is new to thinking about fires and how they should be handled. Knowledge of the physical and chemical - [Multiple-component products needing SDSs](https://ttenvironmental.co.uk/clp-knowledgebase/multiple-component-products-needing-sdss/) - Some hazardous materials are sold in two-packs or three-packs for mixing together by the end user, who would often be a professional user, and therefore require an SDS). The classic example would be a two-part epoxy resin glue. In this situation, an SDS is required for all individual components (if they are all hazardous), so you - [vPvB, very Persistent very Bioaccumulative Substances](https://ttenvironmental.co.uk/clp-knowledgebase/vpvb-very-persistent-very-bioaccumulative-substances/) - Very Persistent very Bioaccumulative Substances, vPvB, is a new type of hazard which was brought into the EU in 2001 , and it has since been brought into the scope of the REACH regulation. The concept is similar to PBT, Persistent, Bioaccumulative and Toxic substances, but this is for non-toxic materials which do not degrade - [Colour Index Names and Numbers](https://ttenvironmental.co.uk/clp-knowledgebase/colour-index-names-and-numbers/) - The Colour Index is used to identify dyes and pigments commercially. It currently contains around 13,000 chemical structures and 37,000 commercial names. Definitions of dyes and pigments are given at https://colour-index.com/definitions-of-a-dye-and-a-pigment . There are two ways that the Colour Index (CI) identifies materials: the CI generic name, e.g. Solvent Red 111 the CI constitution number, - [Selling and advertising CLP products](https://ttenvironmental.co.uk/clp-knowledgebase/selling-and-advertising-clp-products/) - When you sell a CLP-liable product, it must be labelled with the relevant CLP information, allowing for any derogations for pack size. There are also rules for advertising CLP products, which apply to both face-to-face and internet sales, which are found in Article 48 of CLP: for CLP-liable substances, any advert must mention the hazard - [Misleading claims on CLP label or SDS](https://ttenvironmental.co.uk/clp-knowledgebase/misleading-claims-on-clp-label-or-sds/) - Under CLP and REACH, it is prohibited to make misleading claims on a CLP label, packaging or associated Safety Data Sheet which implies that a product which is hazardous is not hazardous; or that it is more safe than the classification indicates; or which contradicts the classification. This includes statements such as ‘non-toxic’, ‘non-harmful’, ‘non-polluting’, ‘ecological’, - [Misleading claims on CLP label](https://ttenvironmental.co.uk/clp-knowledgebase/misleading-claims-on-clp-label/) - Under CLP , it is prohibited to make misleading claims on a CLP label or packaging which implies that a product which is hazardous is not hazardous; or that it is more safe than the classification indicates; or which contradicts the classification. This includes statements such as ‘non-toxic’, ‘non-harmful’, ‘non-polluting’, ‘ecological’, etc. (Note that the prevention of - [Misleading claims on Safety Data Sheet](https://ttenvironmental.co.uk/clp-knowledgebase/misleading-claims-on-safety-data-sheet/) - Under REACH, it is prohibited to make misleading claims on a Safety Data Sheet which implies that a product which is hazardous is not hazardous; or that it is more safe than the classification indicates; or which contradicts the classification. This includes statements such as ‘non-toxic’, ‘non-harmful’, ‘non-polluting’, ‘ecological’, etc. (Note that the prevention of the - [Summary of CLP packaging requirements](https://ttenvironmental.co.uk/clp-knowledgebase/summary-of-clp-packaging-requirements/) - CLP packages are required for all materials classified for CLP. Any CLP material which is packaged according to its specific requirements for Transport is automatically considered to be packaged correctly. Transport of Dangerous Goods requirements refer to the type and construction of the package, and also the ullage, that is the volume any package can - [About CLP Packaging Requirements](https://ttenvironmental.co.uk/clp-knowledgebase/about-clp-packaging-requirements/) - Products classified for CLP are required to meet the packaging requirements within CLP. Any industrial products which are packaged to meet Transport requirements are deemed to meet the CLP Packaging requirements. Consumer and professional products, and any industrial products which are not packaged for Transport have specific requirements under CLP https://ttenvironmenta.wpengine.com/clp-knowledgebase/non-transport-approved-packaging-for-clp-products/ . For consumer goods with specific hazard - [Summary of CLP classification from first principles](https://ttenvironmental.co.uk/clp-knowledgebase/summary-of-clp-classification-from-first-principles/) - CLP classification from first principles is based on obtaining data from published sources, or by testing, and working through the various classification methods in the CLP regulation. There are several types of test used: physical properties of a substance or mixture, and calculating the hazards from the results direct measurement of physical hazards health hazards inferred - [Summary of CLP classification of mixtures](https://ttenvironmental.co.uk/clp-knowledgebase/summary-of-clp-classification-of-mixtures/) - CLP classification of mixtures typically takes place on the basis of test data (physical hazards); or using calculation methods (health and environmental hazards). There are some exceptions, as a few physical hazards can be estimated by calculation or threshold methods; and health and environmental hazards on a mixture which holds test data can be classified from - [Harmonised Classifications List](https://ttenvironmental.co.uk/clp-knowledgebase/harmonised-classifications-list/) - The Harmonised Classifications List is available as Table 3.1 to Annex VI of CLP, and exists within the CLP Regulation and some of its amendments (Adaptations to Technical Progress, ATPs). Note that in the 10th ATP, its name has been changed to Table 3. ECHA provide an Excel spreadsheet for Harmonised Classifications, but this is - [When to classify a mixture for CLP yourself](https://ttenvironmental.co.uk/clp-knowledgebase/when-to-classify-a-mixture-for-clp-yourself/) - CLP mixture classifications are usually carried out by the company making the mixture, or by the company importing the mixture. Mixtures need to be classified for CLP when they are made within the EU, or imported from outside the EU. It is the responsibility of the formulator or importer to classify the mixture for CLP - [Summary of when a mixture needs to be classified](https://ttenvironmental.co.uk/clp-knowledgebase/summary-of-when-a-mixture-needs-to-be-classified/) - Mixtures need to be classified for CLP when they are made within the EU, or imported from outside the EU. It is the responsibility of the formulator or importer to classify the mixture for CLP before placing it on the EU market. As mixture classifications are not publicly available in the way that substance classifications - [Using data from non-CLP Safety Data Sheets](https://ttenvironmental.co.uk/clp-knowledgebase/using-data-from-non-clp-safety-data-sheets/) - Mixture data is not as readily available as substance data, and the main source is from non-CLP Safety Data Sheets. (If the mixture has a CLP Safety Data Sheet is available, it has already been classified for CLP!). Data from non-CLP Safety Data Sheets (SDSs) can be used to classify either substances or mixtures for - [Summary of when a substance needs to be classified](https://ttenvironmental.co.uk/clp-knowledgebase/summary-of-when-a-substance-needs-to-be-classified/) - A substance may need to be classified when: it hasn't been registered for REACH or notified to the C&L inventory, so there is no published CLP classification available there is no alternative classification which can be converted to CLP it is completely new to the EU it is being made or imported at less than 1 - [When to classify a substance for CLP yourself](https://ttenvironmental.co.uk/clp-knowledgebase/when-to-classify-a-substance-for-clp-yourself/) - There are a great many CLP classifications for substances available on the ECHA database, in the Harmonised Classifications list, the REACH dossiers, and the Classification and Labelling (C&L) Inventory. This means that you may be able to use a published CLP classification, rather than going through the process yourself. There are also published non-CLP classifications - [About published non-CLP classifications](https://ttenvironmental.co.uk/clp-knowledgebase/about-published-non-clp-classifications/) - Non-CLP classifications are usually published in supplier Safety Data Sheets (SDSs), such as GHS SDSs, which are likely to be easy to convert to CLP. Other information includes old CHIP SDSs, or non-EU SDSs from other jurisdictions such as the USA or Canada before they adopted GHS. There can also be information on old supply - [Converting other non-GHS classifications to CLP](https://ttenvironmental.co.uk/clp-knowledgebase/converting-other-non-ghs-classifications-to-clp/) - It is theoretically possible to convert other non-GHS classifications (that is classifications other than CHIP or Transport). However, to do this, you would need to know what the classification hazards and thresholds are in the other classification system. If you are not an expert in the original hazard classification system, it may be simpler to - [CLP classifications in REACH dossiers](https://ttenvironmental.co.uk/clp-knowledgebase/reach-dossiers/) - REACH dossiers contain the classification information for REACH-registered substances, and "robust study summaries" for the test data or modelling or read-across methods used to arrive at the classification for each hazard. This makes them a very useful source of information for CLP classifications of substances. REACH registrants are required to consider every single CLP hazard - [Summary of published CLP classifications](https://ttenvironmental.co.uk/clp-knowledgebase/summary-of-published-clp-classifications/) - Published CLP classifications can be found in several places: on the ECHA website Harmonised Classifications CLP classifications in REACH dossiers CLP classifications notified to the Classification and Labelling (C&L) Inventory online or from your suppliers supplier Safety Data Sheets (SDSs) Published CLP classifications for substances can vary in the amount of information they hold, and their - [REACH registration numbers](https://ttenvironmental.co.uk/clp-knowledgebase/reach-registration-numbers/) - REACH registration numbers cannot be used to identify specific chemical substances, and are not valid for identifying chemical substances in CLP and on the Safety Data Sheet. However, they are required to be placed on the Safety Data Sheet where a company (or its supplier) has registered a substance, and this requirement applies to substances in - [REACH Authorisation numbers](https://ttenvironmental.co.uk/clp-knowledgebase/reach-authorisation-numbers/) - REACH authorisation numbers cannot be used to identify specific chemical substances, and are not valid for identifying chemical substances in CLP and on the Safety Data Sheet. However, Authorisation numbers are required to be placed on the CLP label and the Safety Data Sheet for any Authorised substance, in addition to the normal chemical identification numbers - [EC numbers](https://ttenvironmental.co.uk/clp-knowledgebase/ec-numbers/) - EC numbers are used to identify specific chemical substances, and are valid for identifying chemical substances in CLP and on the Safety Data Sheet. EC numbers are issued by the European Community (EC, now the European Union, EU), and have been in use since the early 1980s, when the EINECS list was collated. EC numbers - [After C&L notification](https://ttenvironmental.co.uk/clp-knowledgebase/after-c-and-l-notification/) - Once you have notified one or more substances to the Classification and Labelling (C&L) Inventory, your classification will be published on the C&L database via the ECHA website, which can be accessed directly here: https://echa.europa.eu/information-on-chemicals/cl-inventory-database . Your company will not be publicly identified on the C&L Inventory, as this simply lists the number of companies who - [Filling packages under CLP](https://ttenvironmental.co.uk/clp-knowledgebase/filling-packages-under-clp/) - CLP is silent on how full a package should be filled, however this issue is covered by Transport of Dangerous Goods, so if you are transporting a package, then it is likely to be covered by Transport rules. (This is likely to be the case whether the package is compliant with Transport, or with CLP instead). ADR - [Tactile CLP packaging](https://ttenvironmental.co.uk/clp-knowledgebase/tactile-clp-packaging/) - Products requiring a CLP tactile label or package are given in https://ttenvironmenta.wpengine.com/clp-knowledgebase/tactile-clp-labels/ . However, instead of using at CLP tactile label, an alternative approach is to use CLP packaging which contains the tactile warning instead, and use a normal CLP label. For example, some correcting fluids have the warning triangle on their lid. This type of - [REACH and CLP](https://ttenvironmental.co.uk/clp-knowledgebase/reach-and-clp/) - CLP covers most aspects of communicating the hazards of chemicals to end users, except for Safety Data Sheets, which are covered under the REACH regulation. This means that CLP and REACH interact together to ensure that CLP data is included in REACH SDSs. However, the data generated from substances which are registered for REACH is - [Legal basis of CLP](https://ttenvironmental.co.uk/clp-knowledgebase/legal-basis-of-clp/) - CLP is a directly-acting EU regulation, which means that it is not part of individual EU states' laws, although some individual country laws may refer to it (e.g. for enforcement purposes). It is written by the European Commission, and published in the Official Journal of the European Union, http://eur-lex.europa.eu/oj/direct-access.html . CLP is managed by the European Chemicals - [CLP after Brexit](https://ttenvironmental.co.uk/clp-knowledgebase/clp-after-brexit/) - At the time of writing, 28-03-2017, it is not known whether CLP will be adopted by the UK after Brexit, or whether we will go for immediate adoption of GHS, the Globally Harmonised System, which is the "mother standard" of CLP. TT Environmental is a member of the the Chemical Regulations Self Help Group, which - [CLP Label Languages](https://ttenvironmental.co.uk/clp-knowledgebase/clp-label-languages/) - CLP requires that the language on the label should be an official language(s) of the country where the product is supplied, subject to the requirements of the local Competent Authority (as some may require more than one language). It is legal to have more than one language on the label. CLP prohibits more than one CLP - [Non-Transport-approved packaging for CLP products](https://ttenvironmental.co.uk/clp-knowledgebase/non-transport-approved-packaging-for-clp-products/) - Many hazardous chemicals are packaged in containers approved for Transport under the requirements of the UN Transport system (ADR, IMDG, IATA etc). However, smaller packages and consumer packages may not be approved for Transport, and under CLP these are required to meet certain standards. Where packaging contains hazardous product, and is not approved for Transport: - [Mixture components identified on CLP label](https://ttenvironmental.co.uk/clp-knowledgebase/mixture-components-identified-on-clp-label/) - Mixture components to be identified on CLP label Substances contained in mixtures classified for CLP are required to be identified on the label: if they contribute to the classification of the mixture and are hazardous to health, that is acute toxicity, skin corrosion or serious eye damage, germ cell mutagenicity, carcinogenicity, reproductive toxicity, respiratory or skin - [The IUPAC nomenclature system](https://ttenvironmental.co.uk/clp-knowledgebase/the-iupac-nomenclature-system/) - There is an official naming system, IUPAC, the International Union of Pure and Applied Chemistry, and their official website is at: https://iupac.org/ . The IUPAC system is designed so that the name is derived from the chemical structure, and therefore also allows one to derive the structure of the chemical from the name. IUPAC publish an - [Child resistant fastenings](https://ttenvironmental.co.uk/clp-knowledgebase/child-resistant-fastenings/) - Under CLP, consumer products with specific hazards are required to have child-resistant fastenings on the packages. These hazards are: Acute toxicity Category 1 to 3: H300, H310, H330, H301, H311, H331 STOT single exposure Category 1: H370 STOT repeated exposure Category 1: H372 Skin corrosion Category 1, 1A, 1B and 1C: H314 Aspiration hazard Category ## Categories - [News](https://ttenvironmental.co.uk/category/news/) ## Category - [Published CLP classifications](https://ttenvironmental.co.uk/knowledgebase_category/published-clp-classifications/) - Contains lists of published classifications and published occupational exposure limits - [CLP Building Blocks](https://ttenvironmental.co.uk/knowledgebase_category/clp-building-blocks/) - Contains details of the building blocks of CLP, such as symbols, classifications, precautionary information etc. - [CLP Labels](https://ttenvironmental.co.uk/knowledgebase_category/clp-labels/) - [Printable Infographics](https://ttenvironmental.co.uk/knowledgebase_category/printable-infographics/) - Useful printable infographics and mini posters for your noticeboards or walls. Mainly A4, some A3 size. - [Chemical identification](https://ttenvironmental.co.uk/knowledgebase_category/chemical-identification/) - [FAQS](https://ttenvironmental.co.uk/knowledgebase_category/faqs/) - [About the CLP Classification Process](https://ttenvironmental.co.uk/knowledgebase_category/about-clp-classification-process/) - About the CLP classification process, including the different methods available. - [Safety Data Sheets](https://ttenvironmental.co.uk/knowledgebase_category/safety-data-sheets/) - [Packaging for Supply of Chemicals](https://ttenvironmental.co.uk/knowledgebase_category/packaging-for-supply-of-chemicals/) - [First principles CLP Classification](https://ttenvironmental.co.uk/knowledgebase_category/first-principles-clp-classification/) - CLP classification from first principles, for substances, and for mixtures with test data - [Mixture CLP Classification](https://ttenvironmental.co.uk/knowledgebase_category/mixtures-clp-classification/) - CLP classification for mixtures without data, using bridging principles, algorithms etc - [CLP background](https://ttenvironmental.co.uk/knowledgebase_category/clp-background/) - The history of CLP and its precursor regulations, and how it relates to other chemical regulations in the EU and UK. - [Hazard communication for special cases](https://ttenvironmental.co.uk/knowledgebase_category/hazard-communication-for-special-cases/) - This section includes how to classify, label and write SDSs for special cases, e.g. stabilised products, mixtures containing SVHCs etc - [Published non CLP classifications](https://ttenvironmental.co.uk/knowledgebase_category/published-non-clp-classifications/) - This section includes how to convert from CHIP or other classification methods to CLP - [Scope of CLP](https://ttenvironmental.co.uk/knowledgebase_category/scope-of-clp/) - [Tests to generate CLP classification data](https://ttenvironmental.co.uk/knowledgebase_category/tests-to-generate-clp-classification-data/) - [Chemicals with non-CLP designations](https://ttenvironmental.co.uk/knowledgebase_category/chemicals-with-non-clp-designations/) - [C&L Inventory Notification](https://ttenvironmental.co.uk/knowledgebase_category/c-and-l-inventory-notification/) - [Poison Centre Notification](https://ttenvironmental.co.uk/knowledgebase_category/poison-centre-notification/) - [When a substance needs to be classified](https://ttenvironmental.co.uk/knowledgebase_category/when-a-substance-needs-to-be-classified/) - [When a mixture needs to be classified](https://ttenvironmental.co.uk/knowledgebase_category/when-a-mixture-needs-to-be-classified/) - [Selling and advertising hazardous products](https://ttenvironmental.co.uk/knowledgebase_category/selling-and-advertising-hazardous-products/) - [Safety Data Sheet Sections](https://ttenvironmental.co.uk/knowledgebase_category/safety-data-sheet-sections/) - [Printable forms](https://ttenvironmental.co.uk/knowledgebase_category/printable-forms/) - [EUH Statement Classification](https://ttenvironmental.co.uk/knowledgebase_category/euh-statement-classification/)