Continued from page 22


In comparison to the old law (DPD) a number of changes are introduced by the CLP labelling provisions. Hazard pictograms will be used instead of hazard symbols. Risk phrases are replaced by hazard statements and safety advices are replaced by precautionary statements. Certain supplemental hazard information has been provided by EUH statements in the EU system. Furthermore, two signal words have been introduced by CLP: ‘Danger’ and ‘Warning’. ‘Danger’ is used for severe hazards (e.g. skin corrosion) and ‘Warning’ is used for less severe hazards (e.g. skin irritation). The CLP pictograms consist of red framed diamonds with black symbols on a white background. The hazard pictograms according to GHS/CLP and their codes and identification are shown in Figure 2. For most of the CLP hazard pictograms there is a corresponding hazard symbol in the old DPD labelling system. The new pictograms are ‘gas cylinder’, ‘exclamation mark’ and ‘health hazard’; the so-called ‘St. Andrew’s cross’ of the old system won’t be used under GHS/CLP. While the hazard pictograms, hazard statements, EUH statements and the signal word stated on the label for a given classification (hazard class/category) are clearly defined, the CLP Regulation only provides recommendations for the precautionary statements. The selection of the relevant precautionary statements is under the responsibility of the supplier. Therefore, different precautionary statements on the label for comparable products may result. However, the ECHA Guidance on Labelling and Packaging in accordance with Regulation (EC) No 1272/2008 includes selection tables with useful recommendations on relevant precautionary statements for each hazard class/category.


Certain mixtures containing specific hazardous substances shall be labelled with special EUH statements, even if the mixtures are not classified as hazardous. Particularly relevant for lubricants and mineral oil products are: EUH208 – ‘Contains (name of sensitising substance). May produce an allergic reaction.’ and EUH210 – ‘Safety Data Sheet available on request.’


Relevant changes under the new law (CLP) Besides the labelling also the system, the methods and criteria of the classification of chemicals has been changed. Several changes of the classification criteria may cause that not hazardous classified chemicals under the old law will be identified as hazardous according to CLP or that chemicals will


be classified more strictly under the new law and labelled with different or more hazard pictograms.


For example, the flash point limit for the classification of liquids as flammable has increased from 55°C (old law) to 60°C (CLP), that means liquids with a flash point from > 55°C till 60°C are regarded as flammable liquids according to CLP and must be labelled with the hazard pictogram ‘flame’.


There are also relevant changes for several health hazards, for example, for acute toxicity, corrosion and irritation of skin and eye as well as aspiration toxicity. Under the new law, chemicals can be allocated to one of four acute toxicity categories based on classification limits which partly differ from the old law. Mixtures containing corrosive or irritant components are to be classified more severely under CLP in several cases because concentration limits have partly decreased significantly.


The modified classification criteria of aspiration toxicity are of particular importance for mineral oil products and lubricants. Aspiration means the entry of liquids into the trachea and the lower respiratory system. Hydrocarbons with a low viscosity can cause human aspiration toxicity hazards including severe acute effects on the lungs such as chemical pneumonia and pulmonary injury following aspiration. According to the old EU law substances and mixtures are regarded as aspiration toxic if they contain hydrocarbons in a total concentration of 10% at least and their kinematic viscosity is < 7mm²/s at 40°C. They must be labelled with the hazard symbol Xn and the risk phrase R65 ’Harmful: May cause lung damage if swallowed.’ Under GHS/CLP the classification criterion of the kinematic viscosity increases to < = 20.5 mm²/s at 40°C. That means mixtures containing 10% or more of hydrocarbons are to be classified as aspiration toxic if the kinematic viscosity of the mixture is < = 20.5 mm²/s at 40°C. This significant tightening of the classification criteria may cause that not hazardous classified products according to the old law will become aspiration toxic according to CLP and have to be labelled correspondingly, even if the composition of the products has not changed. This may affect for example metal working oils, hydraulic fluids and other functional fluids on a hydrocarbon base, which contain mineral oils or polyalphaolefines.


If such products meet the specified CLP criteria for aspiration


Figure 1. Elements of the CLP label Continued on page 26


24


LUBE MAGAZINE NO.126 APRIL 2015


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