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:
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.