Why does H317 May cause an allergic skin reaction appear for my mixture for OSHA GHS but not for CLP GHS
H317 – ‘May cause an allergic skin reaction’ is required on a mixture when there’s a skin sensitiser at or above the trigger level. There are differences in the trigger levels between OSHA and CLP.
In CLP: the trigger is 1% for materials classified as Skin Sensitiser category 1 or category 1B; and 0.1% for Skin Sensitiser category.
In OSHA: the trigger is 1% for materials classified as Skin Sensitiser category 1B; and 0.1% for Skin Sensitiser category 1 or 1A.
Therefore if you have a skin sensitising ingredient(s) with classification of Skin Sensitiser category 1 (with no A or B) , and the level present is at or above 0.1% but below 1% then OSHA will show classified result of H317, and CLP will not.
A likely reason for the different implementation is that in CLP there is requirement for lower level sensitiser warnings (EUH208 – Contains (name of sensitising substance). May produce an allergic reaction) which warns about the presence of smaller amounts of sensitisers. However, OSHA does not include a requirement to give lower level sensitiser warnings.