Important changes to P280 in 12th ATP to CLP

Extract from Guidance on labelling and packaging in accordance with Regulation (EC) No 1272/2008 Version 4.0 March 2019, (c) ECHA 2019, all rights reserved

I’ve recently realised just how important the subtle change is to P Statement P280, which has come about in Revision 7 of GHS, and is due to be fully implemented into CLP via the 12th ATP by 17th October 2020.

(As you may be aware, in the UK, Duty of Care under the Health and Safety at Work Act 1974 (as amended) means that we should pass on important information as soon as we get it, which means that we may want to adopt changes like the 12th ATP to CLP updates earlier than the official implementation date).

This change to P280 isn’t just me being a complete nerd (although I’m guilty as charged!).

It’s going to mean practical changes to how people handle their hazardous products, because it allows us to put extra information on the label and SDS about Personal Protective Equipment (PPE).

This makes the P280 changes  important for everyone involved in communicating hazards to people using chemicals, and also for everyone using those chemicals and, we hope, reading the label before they start to use the products.  It’s also going to affect ​people like HSE managers who have to write COSHH assessments based on the Safety Data Sheet.

So what is P280, how is it changing, and why is it such a big deal?

Old P280:  Wear protective gloves/protective clothing/eye protection/face protection​.

New P280:  Wear protective gloves/protective clothing/eye protection/face protection/hearing protection/…​

Recap on writing P statements:

• Where there are slashes, /, this means you can choose which bit of information to place on the label
• Where there is an ellipsis, those three little dots, …, that means you can add extra information

Or, you can read the official ECHA labelling guidance, definitions in the picture at the top of this page.

So the changes to P280 are:  hearing protection/…​  and this means that you can choose to add in hearing protection, if it’s appropriate, and you can also put in your own PPE instructions.

And people who read the label, and assess the risks to users, will be able to see your advice on the label, not just on the Safety Data Sheet (SDS).

This is a big deal, because it means that we can give extra information to end users on the label, that is at the point they use the product.  It’s especially important for consumers, who don’t generally have an SDS.

It’s also important because P280 is one of the most commonly used P-statements:

• H280 by itself applies to Unstable explosive, Explosives 4 & 5, Desensitised Explosives 1, 2 & 3, Pyrophoric Gas 1, Flam Liq 1,2,3 (and 4 under GHS only), Flam Solids 1 & 2, Self reactives A to F, Self heating 1 & 2, Contact with water emit flam. gas 3, Oxidising liquids 1,2,3, Oxidising solids 1,2,3, Organic Peroxides A to F, Germ cell mutagen 1, 1A, 1B & 2, Carcinogen 1, 1A, 1B & 2, and Reprotoxin 1, 1A, 1B & 2
• H280, with guidance on which PPE should be specified (e.g. classifiers of acute dermal toxicity 1,2, & 3 should specify protective gloves and clothing).  H280 with guidance applies to Explosives 1,2 & 3, Pyrophoric Liquids 1, Pyrophoric Solids 1, Acute dermal toxicity 1,2,3, Skin corrosion 1 & 2, Eye damage 1 & 2,  and Skin Sensitisation 1, 1A and, 1B

I know that the thought of specifying extra PPE on the label may make you feel a bit nervous, it certainly worries me.  On the SDS we need to be very, very careful about any specifications for PPE we make.

This is because:

• the wrong type of PPE can be harmful, for example using the wrong type of glove may allow a hazardous liquid to penetrate through to the skin but the user may think they are protected.
• even when the correct PPE is used, it has to be used in the right way to ensure complete protection.  For example, breathing apparatus needs to be fitted properly to ensure that there is a seal so the person is breathing clean air, and that hazardous chemicals cannot be inhaled accidentally.

These reasons are why it is very important to provide the right advice on a Safety Data Sheet, which can involve getting specialist advice from an occupational hygienist about the correct PPE and instructions to put on your SDS.

(By the way, if you want to go beyond a generic statement on your SDS about “using suitable gloves”, and need help with the type(s) of gloves to specify for your product, I thoroughly recommend EnviroDerm Services​,  https://www.enviroderm.co.uk/​.  Chris Packham (not to be confused with the broadcaster and ecology campaigner with the same name) and his small team do excellent work.

But at the moment, we are thinking about P280 as it is used on the label, which is going to be generic advice.

So what type of PPE might we want to include?  The ones which immediately come to mind are:

• dust masks
• respiratory protection, e.g. breathing apparatus etc

​If you already handle products with an inhalation hazard, you will be aware that several P Statements deal with inhalation risks, as follows:

• P260 Do not breathe dust/fume/gas/mist/ vapours/spray.
• P271 Use only outdoors or in a well-ventilated area.
• P284 [In case of inadequate ventilation] wear respiratory protection.

So I think it would be acceptable to add “/respiratory protection” to P280 if you have a product which might have any of these P Statements available, and where the inhalation risk is such that you want to include this on the label. You can then add further information on the type of respiratory protection on the SDS.​ 

I would also think that it would be acceptable to omit P284, because that would be giving the same information twice, but I would not necessarily omit P260 and P271, because they provide extra information (although the choice of P statements is always up to you, the classifier).  

What I’m not sure about is whether it would be appropriate to put in a phrase about dust masks.  

You could argue that this is covered by the phrase “respiratory protection”, but that also covers breathing apparatus, and there are bound to be dusty materials where you would want someone to wear a dust mask.

However, there are different grades of dust mask, depending on the size of dust particle present, and it is easy to have a badly fitting dust mask which does not provide protection.

So I would be wary of advising people to specifically use a dust mask as part of a P statement, especially where they are consumers and do not have access to a Safety Data Sheet where you could specify exactly what should be used.

It will be interesting to see how ECHA provide guidance on this in the Labelling Guidance, but this is unlikely to be issued until after the 12th ATP changes have been brought into effect in October 2020.

It’s fascinating to see how the addition of a slash mark and three small dots can cause quite significant changes to a product label.  If you are a Regulatory Affairs professional, you may want to bring this change to the attention of your Health & Safety colleagues, or vice versa, as it affects people in ​both disciplines, as well as end users of chemicals.

As usual, if you have any queries or comments, please email me.

GHS Classification Courses from TT Environmental Ltd

13th January 2020

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