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twcorthorn  
#1 Posted : 05 September 2025 11:29:31(UTC)
Rank: New forum user
twcorthorn

On A SDS sheet you have a section containing the GHS classiciation pictograms and then further down a list of hazard statements. We have a cleaning product that only shows the classification pictogram for GHS05 (corrosive) and GHS07 (irritant). It does not show the GHS09 (environment). However when you read the list of hazard statements it states H412 Harmful to aquatic life with long lasting effects. Can anyoen give me some idea why there would be no pictogram for environment when H412 is stated below because the bottle itself only shows pictograms and not the additional list of hazards which for us operating a boat company is more important and easily missed.

Roundtuit  
#2 Posted : 05 September 2025 13:27:56(UTC)
Rank: Super forum user
Roundtuit

The environmental pictogram is only mandated in regulation for

H410: Very toxic to aquatic life with long lasting effects - with signal word WARNING

and

H411: Toxic to aquatic life with long lasting effects - no signal word

No signal word or pictogram are required for classifications

H412: Harmful to aquatic life with long lasting effects

or

H413: May cause long lasting harmful effects to aquatic life

thanks 4 users thanked Roundtuit for this useful post.
A Kurdziel on 05/09/2025(UTC), peter gotch on 06/09/2025(UTC), A Kurdziel on 05/09/2025(UTC), peter gotch on 06/09/2025(UTC)
Roundtuit  
#3 Posted : 05 September 2025 13:27:56(UTC)
Rank: Super forum user
Roundtuit

The environmental pictogram is only mandated in regulation for

H410: Very toxic to aquatic life with long lasting effects - with signal word WARNING

and

H411: Toxic to aquatic life with long lasting effects - no signal word

No signal word or pictogram are required for classifications

H412: Harmful to aquatic life with long lasting effects

or

H413: May cause long lasting harmful effects to aquatic life

thanks 4 users thanked Roundtuit for this useful post.
A Kurdziel on 05/09/2025(UTC), peter gotch on 06/09/2025(UTC), A Kurdziel on 05/09/2025(UTC), peter gotch on 06/09/2025(UTC)
Kate  
#4 Posted : 05 September 2025 15:18:01(UTC)
Rank: Super forum user
Kate

Yes, as explained above.  If this is particularly important to you as you mention, you will need to look for the hazard phrase and not just a pictogram.  That it's corrosive should also be a clue that it's likely to be harmful to aquatic life, as corrosives will be either strongly acidic or strongly alkaline (either of which almost no life likes) and this may well be the mechanism of harm in this case.

Roundtuit  
#5 Posted : 05 September 2025 15:41:32(UTC)
Rank: Super forum user
Roundtuit

Originally Posted by: twcorthorn Go to Quoted Post
the bottle itself only shows pictograms and not the additional hazards

Sorry should have addressed this point.

Labelling must include as applicable pictograms, a signal word Warning or Danger, Hazard and Precautionary statements (although the number is permitted to be abridged)

Guidance https://echa.europa.eu/regulations/clp/labelling

If they have only applied the pictograms on the label the supplier is not complying with regulation.

Roundtuit  
#6 Posted : 05 September 2025 15:41:32(UTC)
Rank: Super forum user
Roundtuit

Originally Posted by: twcorthorn Go to Quoted Post
the bottle itself only shows pictograms and not the additional hazards

Sorry should have addressed this point.

Labelling must include as applicable pictograms, a signal word Warning or Danger, Hazard and Precautionary statements (although the number is permitted to be abridged)

Guidance https://echa.europa.eu/regulations/clp/labelling

If they have only applied the pictograms on the label the supplier is not complying with regulation.

HSSnail  
#7 Posted : 08 September 2025 07:21:25(UTC)
Rank: Super forum user
HSSnail

From the HSE poit of view COSHH should have an extra H in it, control of substances hazardouse to HUMAN health. while anything dangerouse to aquatic life should be carefully considered, the HSE would not look at it. If anyone used the old COSHH Essentials web package you would notice some of the hazard phrases were missing - like flamable which HSE think is safey risk and part of your fire RA not COSHH.

Kate  
#8 Posted : 08 September 2025 08:27:54(UTC)
Rank: Super forum user
Kate

It's true that harm to aquatic life, and flammability,  are not part of COSHH, but it is both customary and logical to consider the environmental and fire risks along with the health risks when carrying out a task risk assessment involving chemicals, which then customarily gets labelled a COSHH assessment.

In fact the question was a CLP question not a COSHH question but does it really matter?

Roundtuit  
#9 Posted : 08 September 2025 08:45:17(UTC)
Rank: Super forum user
Roundtuit

Beware goods purchased from overseas if environmental hazards are important.

In some jurisdcistions such as the USA their adoption of the Globally Harmonised System does not include mandatory consideration of environmental hazards as Safety Data Sheets are defined under OSHA regulation and not EPA

thanks 2 users thanked Roundtuit for this useful post.
peter gotch on 08/09/2025(UTC), peter gotch on 08/09/2025(UTC)
Roundtuit  
#10 Posted : 08 September 2025 08:45:17(UTC)
Rank: Super forum user
Roundtuit

Beware goods purchased from overseas if environmental hazards are important.

In some jurisdcistions such as the USA their adoption of the Globally Harmonised System does not include mandatory consideration of environmental hazards as Safety Data Sheets are defined under OSHA regulation and not EPA

thanks 2 users thanked Roundtuit for this useful post.
peter gotch on 08/09/2025(UTC), peter gotch on 08/09/2025(UTC)
HSSnail  
#11 Posted : 08 September 2025 11:58:28(UTC)
Rank: Super forum user
HSSnail

Originally Posted by: Kate Go to Quoted Post

It's true that harm to aquatic life, and flammability,  are not part of COSHH, but it is both customary and logical to consider the environmental and fire risks along with the health risks when carrying out a task risk assessment involving chemicals, which then customarily gets labelled a COSHH assessment.

In fact the question was a CLP question not a COSHH question but does it really matter?

Did i not say it should still be carefully considered, But the question is headed COSHH Query, hence my comment

stevedm  
#12 Posted : 08 September 2025 14:32:03(UTC)
Rank: Super forum user
stevedm

always read the exam question twice....  ;)

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