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ECHA - Guidance of the application of CLP criteria [November 2012]

ECHA - Guidance of the application of CLP criteria [November 2012]

ECHA - Guidance of the application of CLP criteria [November 2012]

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<strong>Guidance</strong> on <strong>the</strong> Application <strong>of</strong> <strong>the</strong> <strong>CLP</strong> Criteria Version 3.0 - <strong>November</strong> <strong>2012</strong>“1.3.2.2.1 The GHS uses <strong>the</strong> term “hazard classification” to indicate that only <strong>the</strong> intrinsichazardous properties <strong>of</strong> substances or mixtures are considered.1.3.2.2.2 Hazard classification incorporates … identification <strong>of</strong> relevant data regarding <strong>the</strong>hazards <strong>of</strong> a substance or mixture …”The following guidance is intended to clarify <strong>the</strong> references to 'reasonably expected use' and'form or physical state' in this context.1.2.2 The term 'reasonably expected use’ in relation to hazard classificationHazard classification is based on intrinsic properties <strong>of</strong> <strong>the</strong> substance and does not take intoaccount exposure. Reasonably expected use summarises all physical forms and states <strong>of</strong> asubstance or mixture that may occur during intended use or reasonably foreseeable conditions<strong>of</strong> misuse.Reasonably expected use <strong>of</strong> a substance is as follows: Any process, including production, handling, maintenance, storage, transport ordisposal. All technical operations/manufacturing activities like e.g. spraying, filing, and sawing Any putative consumer contact through e.g. do-it-yourself or household chemicals. All pr<strong>of</strong>essional and non-pr<strong>of</strong>essional uses including reasonably foreseeable misuse,but not abuse such as criminal or suicidal uses.Reasonably expected use is also related to any consumer disposal or any work in which asubstance or mixture is used, or intended to be used irrespective <strong>of</strong> its present limited use oruse pattern. Thus, use should not be mixed up with usage category.1.2.3 The term ‘form or physical state’ in relation to hazard classificationDepending on different prerequisites, form or physical state is taken into account differentlyin <strong>the</strong> practice <strong>of</strong> testing and classification for physical, health, and environmental hazardswhich is described in <strong>the</strong> following paragraphs.1.2.3.1 Physical hazardsDifferent forms or physical states <strong>of</strong> a substance or mixture may result in different physicalproperties and hazards with possible consequences for <strong>the</strong> hazard classification <strong>of</strong> a substanceor mixture. Putative forms comprise properties such as crystal structure, particle size,homogeneity (e.g. emulsions) and texture (e.g. viscosity or tablet form). Examples <strong>of</strong> physicalstate factors are: surface treatment (e.g. coating), state <strong>of</strong> aggregation, moisture content,residual solvent, activation or stabilisation.The classification <strong>of</strong> a substance or mixture relates to <strong>the</strong> tested form and physical state. If <strong>the</strong>form and / or physical state is changed it has to be evaluated whe<strong>the</strong>r this might affect <strong>the</strong>classification and whe<strong>the</strong>r re-testing is necessary. For example, a hazardous phase separationmay occur due to a temperature change under conditions <strong>of</strong> storage, or a solid substance maybe molten to bring it into <strong>the</strong> liquid phase (e.g. for pumping).General considerationsThe form <strong>of</strong> a substance or mixture as placed on <strong>the</strong> market might be such that it is notpossible to test it in this form, e.g. if it is in <strong>the</strong> form <strong>of</strong> tablets or pellets. In suchcircumstances, <strong>the</strong> physical hazards <strong>of</strong> <strong>the</strong> substance or mixture shall be considered for42

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