Many Substances Are Often More Dangerous Than Their CLP Classification Indicates

Two Austrian hazardous substances experts, Norbert Neuwirth and Joe Püringer, have criticized the CLP classification at the most recent meeting of Competent Authorities for REACH and CLP (CARACAL) at the beginning of July. They stated that many hazardous substances were classified as less dangerous than they actually are. Both authors frame their remarks within the context of a study. They have published their findings in a professional article (available in German only) on the problem of minimum classifications according to the CLP regulation from the viewpoint of work safety.

The CLP Regulation (GHS Regulation (EC) No. 1272/2008) for substances has been in effect since December 1, 2010 and for mixtures since June 1, 2015. The regulation implements a new system for the classification, labeling, and packaging of substances and mixtures across Europe. The CLP Regulation repealed European Directives 67/548/EEC (Substance Directive) and 1999/45/EC (Preparation Directive).

However, the classification criteria in the two regulations do not correlate one to one, so that it is impossible to convert directly from the classification system of the Substance Directive into that of the Preparation Directive. To enable such a conversion, the law provides documents on “Minimum Classification” and a “Translation Table (CLP, Annexes VI and VII).”

Neuwirth and Püringer localize the problem exactly at this point. If the classifiers have no other information, they are to use the classification of a less-dangerous category. For some hazard classification, such as “acute toxicity,” this approach demands considerable shifts – with significant consequences for work and facility safety.

The authors therefore demand a maximum classification instead of a minimum classification and call for the appropriate changes to Annexes VI and VII of the CLP Regulation. In light of the precautionary principle, such a change should pose no legal difficulties.

Ensure the legally compliant classification, labeling, and packaging of your products. If you have any questions, please contact us at clp-info@kft.de.

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