Developed and maintained by the NFCC Contents Transportation, packaging and supply ................................................................................................. 3 Road transportation .......................................................................................................................... 22 Emergency Action Code (EAC) ........................................................................................................... 51 ADR hazard identification numbers (HIN) or ‘Kemler Code’ ........................................................ 55 Packaging ............................................................................................................................................. 62 This content is only valid at the time of download - 30-09-2021 17:53 2 of 72 Transportation, packaging and supply Supply classification and labelling There have been significant changes to the legislation that controls how the hazards of chemical products are classified and communicated. The purpose of supply classification and labelling is to consider the end user of a product. It should ensure they have sufficient information on the hazards of products to enable them to fully assess the risks the product presents in the process in which they use the product. This may be an industrial user, such as an employee in the chemical manufacturing industry or a professional user, such as a hair-stylist or professional gardener who uses chemical products as part of their role. The end user could also be a member of the public, as household products such as bleach and washing detergents can also contain hazardous chemicals. The scope of supply regulations are therefore wider than the transportation regulations, and also include a wider range of hazards, particularly for health hazards where long-term or chronic health effects are also considered. The changes in supply regulations have been driven by the adoption of the United Nations Globally Harmonised System for classification and labelling, typically referred to as UN GHS or just GHS. UN GHS is an international agreement developed to create global standards in two key areas. Firstly, on the criteria for classifying chemicals according to their physical, health, environmental hazards, Secondly on hazard communication requirements through labelling and safety data sheets. UN GHS is a non-legally binding international agreement; countries, or trading blocks such as the European Union, have to create legislation to implement it. In the EU this has been done through the Classification, Labelling and Packaging of Substances and Mixtures Regulation, EC1907/2006, typically referred to as the CLP regulation. CLP replaces previous EU directives that set out the requirements for classification and labelling in Europe, the Dangerous Substances Directive 67/548/EEC and Dangerous Preparations Directive 1999/45/EC. These directives were implemented in the UK under the Chemical Hazard Information and Packaging for Supply Regulations, commonly referred to as the CHIP regulations. The overall concept of CLP has many crossovers with the CHIP regulations: the hazards of the products are classified into specific groups and this information is communicated through a label. However there are some differences between the classification groups and the content of the label information. Comparison of hazard communication under CLP to the CHIP regulations The label is a primary method of hazard communication under both the old CHIP regulations and under CLP. Table 15 shows how the structure of the labels are effectively quite similar, but there This content is only valid at the time of download - 30-09-2021 17:53 3 of 72 are some differences to how the data is presented as described: Table 15 CHIP and CLP label comparison CHIP Label CLP Label Indications of Danger: Signal Word: • Explosive • Danger • Oxidising • Warning • Extremely flammable • (None) • Highly flammable • Very toxic • Toxic • Harmful • Corrosive • Irritant • Dangerous for the environment Symbols Pictograms Risk phrases: Hazard statements: • Highly flammable • Highly flammable liquid and vapour • Very toxic by inhalation • Fatal if inhaled • Causes burns • Causes severe skin burns and eye damage Safety phrases: Precautionary statements: • Keep container tightly closed • Keep container tightly closed • Avoid contact with skin and eyes • Do not get in eyes, on skin or on • Wear suitable protective clothing clothing • Wear protective clothing How does the GHS classification system work? GHS splits the hazards from chemical products into three types – physical, health and environmental hazards. Within these hazard types are hazard classes that describe the nature of This content is only valid at the time of download - 30-09-2021 17:53 4 of 72 the physical, health or environmental hazard. Using physical hazards as an example, the following hazard classes are given: Explosives Flammable gases Aerosols Oxidising gases Gases under pressure Flammable liquids Flammable solids Self-reactive substances and mixtures Pyrophoric liquids Pyrophoric solids Self-heating substances and mixtures Substances and mixtures that emit flammable gases when in contact with water Oxidising liquids Oxidising solids Organic peroxides Corrosive to metals Each hazard class is then further divided into a number of hazard categories. These are represented by numbers, and are used to indicate the severity within the hazard class. A hazard category 1 represents the most severe hazard. The severity of the hazard then decreases as the number increase. The table below shows how the hazard categories are differentiated using flammable liquids as an example. Table 16 Flammable liquids hazard category Hazard category Criteria 1 Flash point < 23oC and initial boiling point ≤ 35oC 2 Flash point < 23oC and initial boiling point > 35oC 3 Flash point ≥ 23oC and ≤ 60oC Table 17 below demonstrates when a product has been confirmed to meet the criteria for a hazard class and category. The CLP regulation indicates the pictogram, signal word, hazard statements and precautionary statements that have to be used on the product packaging. For a liquid product with a flashpoint measured at 31oC, and boiling point measured at 60oC the product would be classified as a Flammable liquid, category 2. The regulation then provides the following hazard communication information: This content is only valid at the time of download - 30-09-2021 17:53 5 of 72 Table 17 CLP hazard and precautionary statements Pictogram: Signal word: Danger Hazard statement: H225 Highly flammable liquid and vapour. Precautionary statements: • P210 Keep away from heat, hot surfaces, sparks, open flames and other ignition sources. No smoking • P233 Keep container tightly closed. • P240 Ground/bond container and receiving equipment • P241 Use explosion-proof electrical/ventilating/lighting/equipment • P242 Use only non-sparking tools. • P243 Take precautionary measures against static discharge. • P 280 Wear protective gloves/protective clothing/eye protection/face protection. • P303 + 361 +353 IF ON SKIN (or hair): Take off immediately all contaminated clothing. Rinse skin with water/ shower. • P370 + 378 In case of fire: Use water to extinguish. • P403 + 235 Store in a well-ventilated place. Keep cool. • P501 Dispose of contents/container to … In practice, a maximum of six precautionary hazard statements should be used on a product label, and the regulation provides further guidance on how to refine the precautionary statements so that an acceptable number are used on the label. Once the full range of physical, health and environmental hazards of a product have been classified according to the CLP classification rules, a label for the product can be created. The following information must be included on the label: Name, address and telephone number of the supplier(s) Nominal quantity of the substance or mixture in the package made available to the general public, unless this quantity is specified elsewhere on the package Product identifiers (name) This content is only valid at the time of download - 30-09-2021 17:53 6 of 72 Hazard pictograms Signal word Hazard statements Precautionary statements The label must also be in the official language for the country it will be sold in. So for any product supplied into the UK, the language used on the label must be English. Table 18 below describes how the label used must also meet minimum size requirements. Table 18 CLP label, minimum size requirements Minimum dimensions of the label Capacity of package (mm) Not exceeding 3 litres 52 x 74 Greater than 3 litres, but not exceeding 50 litres At least 74 x 105 Greater than 50 litres, but not exceeding 500 At least 105 x 148 litres Greater than 500 litres At least 148 x 210 CLP label example This content is only valid at the time of download - 30-09-2021 17:53 7 of 72 Links between CLP regulation and dangerous goods transportation regulations. The UN GHS classification guidelines are issued through a UN document referred to as the purple book. They form the basis for the European supply regulation, the Classification, Labelling And Packaging Of Substances And Regulations (CLP). Diagram 2 below describes the classification rules used by UN GHS, which also form the basis for the classification rules used in transportation regulations: Diagram 2 Classification rules used by UN GHS This content is only valid at the time of download - 30-09-2021 17:53 8 of 72 This ensures that the classification rules match between the