GHS & CLP - Data & Information FAQ
How much time do I have to change the classification of a substance or mixture upon development of new toxicity/ecotoxicity information that changes the classification?
Your labels should be updated without undue delay following any changes to the classification and labelling of your substance or mixture where the hazard is more sever or where new supplemental labelling elements are required.
Where other labelling elements are required (i.e. Change in telephone number, less sever hazard etc) you shall ensure that the label is updated within 18 months.
Is physico-chemistry testing needed if no reliable data is available?
Yes. If no reliable data is available, for the purpose of determining whether a substance of mixture entails a health or environmental hazard, the manufacturer, importer or downstream user may perform new tests (CLP Art 8(1)). To determine if the substance or mixture entails any of the physical hazards (as in Part 2 of Annex I), the manufacturer, importer or downstream user shall perform tests required in that part, unless there is adequate and reliable information already available (see CLP Art 8(2)).
Is there an outlined methodology for using read-across?
Yes. How to apply it to metals, metal compounds will be outlined in a paper to be published in 2009, based on the experiences from the metals consortia, the HERAG approach. Guidance is already available on the ECHA website: Guidance on information requirements and chemical safety assessment, Chapter R.6: OSARs and grouping of chemicals.
What is bridging? And how important is it?
Bridging principles are used when there them mixture itself has not been tested to determine its hazardous properties, but there are sufficient data on similar tested mixtures and individual hazardous ingredient substances to adequately characterise the hazards of the mixture. These data shall be used in accordance with bridging rules (referred to in Article 9(4)) for each individual hazard class. The bridging rules consider such instances of differences between tested mixtures and non-tested mixtures (i.e. dilution, batching, concentration of highly hazardous mixtures etc). (See section 1.1.3 in Annex I of CLP for complete bridging rules).
NOTE: Read-across/ bridging can be a very powerful tool, saving a lot of testing. It should however be well thought through and performed by experts. If done inappropriately or too hasty, it could lead to many unwanted classifications.
What is the minimum phys-chemistry data for CSA/CSR (REACH)?
As a minimum, the potential effects to human health shall be assessed for the following physicochemical properties: Explosivity, flammability, oxidising potential. If the information are inadequate to decide whether a substance should be classified for a particular endpoint, the registrant shall indicate and justify the action or decision he has taken as a result. (Please refer to REACH Annex I)
Last page update: 1 October 2018