Rules for Precautionary Statements for products under CLP

Rules for Precautionary Statements for products under CLP

What are the rules for selecting precautionary statements for a consumer product under CLP?

Precautionary statements are tricky. The key thing is the precautions should be targeted at the user, for the specific product taking into account the hazards. The CLP definition is:

‘Precautionary statement’ means a phrase that describes recommended measure(s) to minimise or prevent adverse effects resulting from exposure to a hazardous substance or mixture due to its use or disposal;

For example 5% fragrance in aerosol vs in candle is a different product and has a different way of being used, potentially a different ‘exposure’, so may have different precautions. An aerosol air freshener designed to be dispensed on demand by a consumer vs a controlled release metered dose air freshener may have different precautions also. So, the person responsible for placing the product on the market needs to make an informed decision in selecting appropriate Precautionary Statements. The CLP Wording is:

Article 28.
Principles of precedence for precautionary statements
1. Where the selection of the precautionary statements results in certain precautionary statements being clearly redundant of unnecessary given the specific substance, mixture or packaging, such statements shall be omitted from the label.
2.Where the substance or mixture is supplied to the general public, one precautionary statement addressing the disposal of that substance or mixture as well as the disposal of packaging shall appear on the label, unless not required under Article 22.
In all other cases, a precautionary statement addressing disposal shall not be required, where it is clear that the disposal of the substance or mixture or the packaging does not present a hazard to human health or the environment.
3.Not more than six precautionary statements shall appear on the label, unless necessary to reflect the nature and the severity of the hazards.

Some reasonable views are: if it’s for a consumer product then workplace precautions are probably redundant but if it’s industrial / institutional then they should be considered.

Please note, Formpak software is primarily used by Business to Business users and the automatic generation of Precautionary statements relate to these types of users. If the product is a consumer product there are certain precautions that may be useful or necessary, but these would not automatically be populated by Formpak. As with all properties, it is possible to manually modify the item to show less, more or different precautions.


Last updated Sept 2015
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