12th ATP Amendments to CLP

Bringing the 6th and 7th revisions of GHS into CLP

One of my tasks is working through the 12th ATP amendments to CLP, which came out in late March, and which were published after the 13th ATP.

I don’t know about you, but this is the sort of thing that makes me very confused about European legislation, as if CLP and REACH weren’t complicated enough.

The reason for the delayed publication is because ECHA give their technical amendments to CLP these tracking names in the right order, but sometimes they go through the process of checking and approval process faster than the previous amendment.

This approval process isn’t just in Europe, any drafts to CLP also have to go to the UN for sign-off, and I would imagine that any version of UK-GHS will also have to go to the UN in the future (if we ever get Brexit, but that’s a different story).

You can download the current consolidated version of CLP (1st March 2018), and the 13th and 12th ATPs from ECHA’s website at https://echa.europa.eu/regulations/clp/legislation.

The headline changes in the 12th ATP are:

  • New cut-off values for inhalation hazards in Table 1.1, and for including in mixture classification
  • A whole new hazard class of desensitised explosives has been introduced
  • The flammable gases/ pyrophoric gas/ chemically unstable gas categories have all been consolidated under the flammable gas category
  • There have also been a number of other changes e.g. an addition to first principles classification for explosives and aerosols

The new cut-off values are:

  • Specific Target Organ Toxicity, Category 3, Single Exposure, H335, May cause respiratory irritation, and H336, May cause drowsiness or dizziness, now have a cut-off value of 1% (unless there’s evidence they may give an effect at a lower concentration)
  • Aspiration Toxicity, Category 1, H304, May be fatal if swallowed and enters airways, now has a cut-off value of 1%

The desensitised explosives changes include:

  • 4 new hazard categories (1 to 4), and 3 new hazard statements: H206, Fire, blast or projection hazard; increased risk of explosion if desensitizing agent is reduced; H207, Fire or projection hazard; increased risk of explosion if desensitizing agent is reduced; and H208, Fire hazard; increased risk of explosion if desensitizing agent is reduced.
  • These all have the flammable symbol, GHS02, rather than the explosives symbol
  • A brand new P statement, P212, Avoid heating under confinement or reduction of the desensitizing component has been created. This applies to all four desensitised explosive classifications, and also to unstable explosives
  • EUH Statement EUH001, Explosive when dry has been removed. Any substance which would have attracted this EUH Statement will now come under the new desensitised explosives class within GHS.

The flammable gas changes include:

  • splitting category 1 into 1A and 1B
  • moving pyrophoric gas and chemically unstable gases into the flammable gas category officially, so these gases will now have 2 H codes/ Hazard Statements to describe them as both flammable gases and their other hazards (this was done by applying both Hazard Statements separately, but this change makes it a bit neater)

These 12th ATP changes mean that CLP is now fully aligned with Revision 7 of GHS …. just in time for GHS Revision 8 to be published, which is due out soon. (I really must find an emoji for banging one’s head against a brick wall!).

There is also a 14th ATP to CLP in the pipeline, although this has been held up because it includes the proposed classification of Titanium Dioxide as a carcinogen, which is being opposed by several Competent Authorities on technical grounds, and I hope to discuss this issue in another email soon.

Stats for the nerdy (like me!): There are currently 113 GHS hazard statements, of which 104 have been adopted into CLP, and 9 are the low-level hazards which look like they never will be adopted. However, we still have 21 EUH Statements which are part of CLP only, so 104 out of 125 CLP hazards, that is 83.2 % of CLP hazards come from GHS. And there are more changes to come!

When CLP was first published, the figure was around 56%, so they are becoming more closely aligned, but at this rate it will take decades to get all of the EUH Statements adopted into GHS, which the EU have said they want to achieve.

GHS Classification Courses from TT Environmental Ltd

30th June 2019

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