How CLP and GHS are related

You’ll probably have seen CLP referred to as CLP-GHS sometimes, and you may be aware of how GHS is the “mother” standard of CLP in the EU. You may even be aware that REACH also plays a part in GHS in the EU, as per the diagram above.

But exactly which parts of GHS are within CLP, which bits of CLP come from CHIP, and what parts of GHS are covered by REACH?

How does GHS affect CLP?

And how does CLP in the EU interact with other GHS jurisdictions around the world?

I’ll go through each of these questions in turn.

Which parts of CLP come from which other source?

The parts of CLP which come from GHS are:

• Hazard information
• How the classification method works
• How hazard information and other information such as product identifiers and supplier information must be laid out on the label

The GHS hazard information comprises:

• Classifications (Hazard Class & Hazard Category) (but some are not used under CLP, see below)
• Symbols
• Signal Words
• Hazard Statements
• Precautionary Statements

The GHS classification method is also used within CLP:

• Obtain the classification by comparing test data with thresholds (substances, physical hazards of mixtures, mixtures where test data is available) or by comparing the percentages of classified components with different thresholds (health and environmental hazards of mixtures)
• Derive the other hazard information, symbol(s), signal word, hazard statement and precautionary statements for each classification the product holds
• Apply precedence to the hazard information, so that there is no more than 1 instance of each applicable symbol on the label; there are no redundant or confusing hazard statements; and no more than 6 or 7 precautionary statements appear on the label
• Compile the label information for printing

GHS goes on to place the classification, label information and test data in a standard format Safety Data Sheet, but in the EU this is handled under REACH, Annex II.

How hazard information and other information such as product identifiers and supplier information are laid out on the label is adopted into CLP straight from GHS, although CLP does provide for extra supplementary information beyond what GHS publishes.

There are two parts of CLP which come from CHIP, its predecessor:

• The Harmonised Classification (from the old Approved Supply List)
• EUH statements (from old Risk Phrases which have not been brought into GHS, or from non-GHS hazards the EU think are important)

Both of these are permissible under GHS, which assumes that each jurisdiction will have its own list of mandatory classifications for certain substances which either are not hazardous themselves in the way the GHS thresholds predict; or their mixtures are not hazardous (more or less hazardous) than the classification algorithms suggest; or both.

GHS also allows for labelling statements to be used where a jurisdiction recognises hazards over and above those within GHS, which is what the EUH statements cover.

Finally, as mentioned above, Safety Data Sheets (as required by GHS) are handled separately under the REACH regulation.

To summarise, GHS provides the “engine room” of CLP classification, including the language of classification (text, symbols, signal word), CHIP provides the mandatory classifications and some extra labelling hazards, and REACH handles Safety Data Sheets for GHS separately from CLP.

However, there are some differences between GHS and CLP:

GHS is currently on Revision 8, whereas CLP is on Revision 7, so the most recent provisions don’t apply. For more information, see our previous article here: https://www.ghsclassificationcourses.com/ghs-revision-8/

Specifically, the new hazard class of chemicals under pressure, and it’s associated hazard classifications and hazard statements is not in CLP yet:

• Chem. press. 1, H282, Extremely flammable chemical under pressure: may explode if heated
• Chem. press. 2, H283, Flammable chemical may explode if heated
• Chem. press. 3, H284, Chemical under pressure, may explode if heated

Some of the lower level hazards within GHS have not been brought into CLP, and are unlikely to be in the future, including:

• Flam. liq. 4, H227, Combustible liquid and vapour
• Acute tox. 5, Oral, H303, May be harmful if swallowed
• Aspiration tox. 2, H305, May be harmful if swallowed and enters airways
• Skin irrit. 3, H316, May cause skin irritation
• Eye irrit. 2B, Causes eye irritation
• Acute tox. 5, Dermal, H313, May be harmful in contact with skin
• Acute tox. 5, Inhal., H333, May be harmful if inhaled
• Aquatic acute 2, H401, Toxic to aquatic life
• Aquatic acute 3, H402, Harmful to aquatic life

This is best shown in a diagram, GHS classifications and whether adopted into CLP to rev 8 GHS

Please email me if you’d like a pdf copy of this.

You can see that there is a built-in discrepancy between the current revision of GHS and the current version of CLP. Not only that, but it can take several revisions before CLP is updated, for example the 12th ATP in 2019 brought both the 6th and 7th revisions of GHS into effect, and its provisions have not fully taken effect yet.

How does GHS affect CLP?

GHS affects CLP through its updates every 2 years. If a new hazard classification is introduced, and CLP adopts it, then that’s a major change; or if any of the existing hazards which are already in CLP are changed, for example classification thresholds or guidelines, then CLP is changed as well.

CLP does not directly affect GHS, although the EU did lobby for hazards to the ozone layer category 1, H420, Harms public health and the environment by destroying ozone in the upper atmosphere, to be brought into GHS. This had previously existed as an EUH statement, EUH059, Dangerous for the ozone layer, which was based on a CHIP classification, R59 Dangerous for the ozone layer.

However, the impact of CLP on GHS is limited to whatever the EU wish to put forward for consideration, and even then its proposals may not be adopted.

How does CLP in the EU interact with other GHS jurisdictions around the world?

The first thing to be aware of is that GHS is not a fixed standard, it’s something which is changing. There are official updates every 2 years, in even years (opposite Transport, which is updated every odd year).

Unlike Transport, which has to be adopted at the same time and in the same way across the world (in general), GHS has been set up so that countries can adopt which bits they like, when they like.

Which is why GHS itself is on Revision 8; the EU is on Revision 7; and the USA is on Revision 3!

This is a concern, because some of the GHS revisions change how chemicals are classified, and the fact that there are different revisions in use mean that there may be important differences in what a GHS classification is perceived to be between two countries. There may be some countries which are on even older versions of GHS, for more details see implementation details at https://www.unece.org/trans/danger/publi/ghs/implementation_e.html.

Apart from being based on different revisions of GHS, which may give rise to subtle classification differences between GHS jurisdictions, there is another problem with translating GHS classifications between different countries.

This is that each individual country, or GHS jurisdiction (in the case of CLP from the EU), is permitted to hold its own list of mandatory or recommended classifications, which override the standard GHS classification methods.

Unfortunately, countries are choosing to have different chemicals in their inventories, and also to classify the same chemical differently. Even the UN has failed to reach agreement on a couple of substances which were meant to be the foundation of a global list of hazard classifications for supply. With the benefit of hindsight, it is surprising that the GHS committee did not use the Dangerous Goods list as the basis of a mandatory classification list.

Of course, allowing different mandatory inventories is another way in which substance classifications (and mixtures containing those substances) may vary between GHS jurisdictions.

So if you are going to translate GHS classifications into CLP, and vice versa, it’s really important to understand which revision of GHS it was classified under, and whether each substance holds a mandatory classification under one or both regimes.

Now we’ve looked at GHS and how it affects CLP, next week I’ll be looking at how REACH and CLP combine to cover all of GHS, and how they interact together.

GHS Classification Courses from TT Environmental Ltd

25th November 2019

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