Twelfth Adaptation to Technical Progress for the CLP Regulation.
The 12th Adaption to Technical Progress (ATP) of the Classification, Labelling and Packaging (CLP) Regulation will apply from 17 October 2020.
The harmonised classification and labelling of hazardous substances is updated through an "Adaptation to Technical Progress (ATP)" adopted yearly by the European Commission, following the opinion of the Committee for Risk Assessment (RAC). Other changes to the legal text may also be implemented through an ATP.
The 12th ATP implements the 6th and 7th amendments of the Globally Harmonised System of classification and labelling of chemicals.
It was published in the EU Official Journal on 27 March 2019. It entered into force 20 days after its publication and the changes will apply from 17 October 2020.
It has significant effect for some gases.
a. New subcategories 1A and 1B for flammable gases (H220, Cat 1A (current cat 1 hazard statement), H221 Cat 1B)
b. In the absence of data allowing classification into Category 1B, a flammable gas that meets the criteria for Category 1A is classified by default in Category 1A (i.e. no fundamental burning velocity data). CO would be 1B, for example. 8 EIGA gases would become 1B
c. New subcategory for pyrophoric gases (H232) (5 gases)
d. In the absence of data on its pyrophoricity, a flammable gas mixture shall be classified as a pyrophoric gas if it contains more than 1 % (by volume) of pyrophoric component(s)
e. Lower Explosive Limit needs to be calculated (as per ISO 10156: 2017)
Insofar as labels are concerned then no real big issue since category 1A is the current method and is the more stringent even though the H phrases are different. There is a difference in labelling for pyrophoric gases where a new subcategory is introduced and hence a new label is required.
All data sheets for flammable gases will need to be revised.
16 October 2020