12th ATP in European Union published, amending CLP to Revisions 6 and 7 of GHS

 The European Union has published the 12th adaptation to technical progress (ATP) to the Regulation (EC) No 1272/2008 on classification, labelling and packaging of substances and mixtures, better known as CLP. The ATP amends the CLP to follow the changes in the UN 6th and 7th biannual revision of the Globally Harmonized System of Classification and Labeling (GHS), which appeared in 2015 and 2017.

Companies have until 17 October 2020 to introduce changes to their process for the creation of safety data sheets and labels to the new requirements. There is no provision for products on the market at that date to continue to be sold under their existing labels for another two years, which has been a usual accomodation to help companies manage the transition after a significant amendment of CLP.

The main changes introduced by the 12th ATP to CLP include:

  • a new hazard class for desensitised explosives; changes to the classification criteria for substances and mixtures which, in contact with water, emit flammable gas;
  • Within the hazard class flammable gases, the ATP adds a new hazard category, pyrophoric gases, and splits the former category 1 in to subcategories 1A and 1B, with the clarification that gases with pyrophoric and/or chemically instable properties must always be considered to be flammable gases of subcategory 1A; 
  • changes to the classification criteria for explosives; 
  • changes to the classification criteria for substances and mixtures which, in contact with water, emit flammable gas;
  • the cut-off value to take into account ingredients with an aspiration hazard during hazard classification of a mixture is finally specified at >=1%, a long-overdue clarification of confusing legal text on this issue. 

The 6th revision of GHS makes substantial changes to the guidance for content of section 9 of the SDS, which should be taken into account for products on the European market. Although the Annex II to REACH, which sets out the requirements for the SDS form and content, has not been updated to the newest GHS recommendations, it does provide that 'other information' should be specified.

Many other miscellaneous changes merit reading, especialy by those charged with establishing correct hazard classifications for substances and mixtures or ensuring the correct label elements and information appears on labels and in safety data sheets.  

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