Last reviewed 23 August 2023
While a great deal of attention is paid by suppliers to selecting the correct pictograms, signal words and hazard (H) statements to go on a label — and rightly so — the selection of precautionary (P) statements is often more of an afterthought. However, there are a number of factors to consider when selecting and completing P statements, and these are considered in this article.
The rules for selecting P statements are given in Article 22 of the EC Regulation 1272/2008 on the classification, labelling and packaging of substances and mixtures (CLP Regulation). These rules include that P statements:
should be selected from those identified in the tables for each relevant hazard class
should be selected taking into account the relevant intended and identified uses
must be worded as given in Annex IV and that where appropriate
must be completed according to the rules set out in the beginning of Annex IV.
This may be straightforward if a product has just one relatively minor hazard classification, however, for products that are classified for several different hazards, the number of applicable P statements can easily add up to 20–30 statements. How do you select relevant P statements in this case?
Selecting P statements
Article 29 sets out the principles of precedence for selecting P statements including that:
redundant and unnecessary P statements should be omitted
a P statement on disposal should be included for substances and mixtures sold to the general public, unless it is clear that the disposal of the product or its packaging does not present a hazard to human health or the environment
normally not more than six P statements are needed on the label, unless the nature and severity of the hazards requires more.
The CLP guidance on labelling and packaging provides a good deal of help in identifying the most appropriate P statements for a product. For each hazard class/category, the P statements given in the tables of labelling information in Annex I of CLP are ranked using what is described as a “traffic light system” where each statement for a particular hazard class/category is ranked as “highly recommended”, “recommended”, “optional” and “not to be used”. The guidance suggests that those statements that require the most immediate action should be prioritised for inclusion on the label, for example, immediate first-aid phrases, where a delay in taking action might result in harm to the user. For statements that are less of a priority, the good advice in these statements can instead be given in a safety data sheet (SDS), for industrial and professional products, or other documentation such as an instruction leaflet for consumer products.
While consideration should be given to the recommendations in the guidance as to which statements should be prioritised, it should also be remembered that these are just recommendations, and depending on the particular products supplied and their intended uses, there may be very good reasons for selecting P statements differently to the guidance.
For consumer products supplied to general public, consideration also need to be given to the inclusion of the P statements: P101, P102 and P103. These won’t appear in the hazard class/category tables, but phrases such as P102 Keep out of the reach of children are important safety messages that should be included for these types of products.
Completing P statements
Once you have made your selection of up to six P statements, you might think that is the end of the story. However, you now need to check whether any of the P statements need completing before use. This applies particularly to those statements that contain a forward slash “/”, those with part of the phase in square brackets “[…]” and those with three dots “…” (Introductory paragraphs to CLP Regulation, Annex IV).
When a forward slash “/” appears in a P statement text, it indicates that a choice has to be made between the various phrases it separates. For example, when using the P Statement P280 Wear protective gloves/protective clothing/eye protection/face protection, consideration should be given to whether all of these protective measures are indeed required or if less personal protective equipment (PPE) is required. If less is needed, the statement could be amended to read “Wear eye protection” or “Wear protective gloves” or “Wear protective gloves and eye protection”. Making sure that only the relevant PPE is selected will help your customers avoid unnecessary PPE which may be expensive and awkward to wear. Removing unnecessary text may also be helpful where label space if very tight.
Checking the requirements of this phrase will also become more important in future, as the Globally Harmonised System of Classification and Labelling of Chemicals (GHS) subcommittee of experts recently (2016) approved a change to this phrase to “Wear protective gloves/protective clothing/eye protection/face protection/hearing protection/… ”. This change was made to take into account concerns expressed in particular about hearing loss from exposure to noise in the use of explosives. Clearly, it would not be desirable to recommend in every case that hearing protection is needed unless loud bangs or other noise are anticipated in use. This change was incorporated into the 7th revised edition of the GHS in 2017.
Similarly, square brackets […] may appear around some text in a P statement to indicate that the text in square brackets is not appropriate in every case and should be used only in certain circumstances. Further guidance as to what these circumstances are will be given in Column 5 of the table of P statements in Annex IV Part 1. Currently, this requirement only applies to P284 [In case of inadequate ventilation] wear respiratory protection.
When three full stops “…” appear in the text of a P statement, they indicate that additional information needs to be provided to complete the statement. The most commonly encountered P statement with this requirement is P501 Dispose of contents/container to… This statement is often completed with the catch-all phrase “in accordance with local/regional/national/international regulations”. If supplying to industrial users, it is reasonable to think that the users may have some ideas as to what local/regional/national/international regulations may actually apply to them, although more detailed advice should be given in the SDS if possible. If, however, you are using this phrase to fulfil the requirement in Article 29 for a disposal phrase to be used for products supplied to the general public, would you expect the end users to have any idea about what regulations may apply to the disposal of the product? Wherever possible, more specific advice should be given such as “Dispose of contents/container to municipal collection point” (also bearing in mind that as the forward slash is included, a choice should be made between contents, container or both).
The selection of P statements is sometimes a bit of an afterthought when determining label information, however, as can be seen above, there are a number of important points to consider when selecting and completing these statements to make sure that labels provide the best possible information for customers. The ECHA guidance document of safety data sheets is an excellent resource to help with choosing precautionary statements.