Proper Labeling of Hazardous Chemicals in Accordance with Regulations - II

Precautionary Statements (Regulation No. 28848, Article 24 and Article 30)

The complete list of precautionary statements is presented in Annex 4 of Regulation No. 28848. The descriptions included in precautionary statements must comply with the second section of Annex 4. Precautionary statements that are clearly excessive or unnecessary for a substance, mixture or package shall not appear on the label. No more than six precautionary statements shall appear on the label unless necessary to specify the severity and nature of the hazard. This provision is frequently misunderstood in practice. If deemed necessary, more than six P statements may be used. The regulation permits this situation. Because sometimes when many H statements are present for products, six P statements may not be sufficient to take the necessary precautions. However, considering that labels must be simple and understandable as a fundamental principle, I would recommend not exceeding ten P statements. When selecting P statements, product characteristics should be considered. The selection should be made taking into account the form in which the product is placed on the market, packaging shape/volume, transport method and similar conditions. For example, static electricity and grounding precautions may be preferred for large volume packages or tanker transport. If transported in 1 L packaging, these precautions may not be used on the label. As another example, if there is no possibility of dust formation from a solid product, the statements "P260 Do not breathe dust" or "P261 Avoid breathing dust" need not be used. Some P statements can be determined by the supplier. P501 is one of these and is the most frequently used. This P statement can be prepared with the recommendation that the supplier deems most appropriate. • Dispose of contents/container in accordance with local regulations, • Dispose of contents/container in accordance with regional regulations, • Dispose of contents/container in accordance with national regulations, • Dispose of contents/container in accordance with international regulations, • Dispose of contents/container to….

Supplemental Hazard Information (EUH codes and statements)

Regulation No. 28848 provides all EUH statements and their conditions of use on labels in Annex 2. For substances and mixtures that present physical hazard, hazard to human health and environmental hazard, they are applied to the label if they meet their own conditions of applicability. Before suppliers prepare labels, that is, before determining the hazard classifications of products and preparing the safety data sheet, EUH statements must be identified. Not all EUH statements may be applicable to every company's products. For this reason, supplier companies must examine Annex 2 and identify EUH statements that may be applicable to the products they place on the market. Some commonly encountered EUH statements and their conditions of use are given as examples below. • For mixtures containing active chlorine sold to the public and containing more than 1% active chlorine, the following statement appears on the labels: EUH206 – "Warning! Do not use together with other products. May produce dangerous gases (chlorine)," • EUH066 – "Repeated exposure may cause skin dryness or cracking," Used for substances and mixtures that may cause skin dryness or cracking problems but do not meet the skin irritation criteria given in section 3.2 of the third part of Annex 1 based on applicable observations; or relevant evidence concerning their predicted effects on skin.

Label Language

Labels of hazardous substances and mixtures placed on the market in Turkey shall be prepared in Turkish. Suppliers may use different languages in addition to Turkish on their labels, provided that the same details appear in all languages used. If a multilingual label is prepared, label elements are presented together for each language.

Labelling Dimensions (Regulation No. 28848, Annex 1)

The starting point for determining labelling dimensions is the size of the package. The label area and the edge length of each pictogram are determined according to the package size. The minimum area of each hazard pictogram shall not be less than 1 cm². The minimum dimensions of labels and pictograms are given below. These areas apply to the area where the mandatory label elements mentioned above are provided and do not include the area where the supplier's own supplemental warnings for the product or supplemental warnings based on official regulations published depending on the product type are located. The regulation does not provide for the character and height of text on the label. It is stated that label information must be legible and in a contrasting color to the background. In addition to the elements mentioned above, different product types may contain additional labelling elements. These additional elements are determined by official regulations issued by the official institution (Ministry) to which the product is subject. For example, 1. Biocidal products include additional label elements specified in the relevant regulation under the scope of the Ministry of Health, 2. Plant Protection Products include additional label elements specified in the relevant regulation under the scope of the Ministry of Food, Agriculture and Livestock, 3. Air freshener products, Detergents, Strong Acid-Base products include additional label elements specified in the notifications for product types under the scope of the Ministry of Customs and Trade.

Labelling of 125 ml and Smaller Packages

When the package is 125 ml or less, the label area may not be sufficient for label elements to fit. The regulation has introduced a practical approach in response to this situation. For certain hazards, hazard statements, precautionary statements and in some cases even the warning word and hazard pictogram need not be used. Detailed explanation of this exceptional situation is given in Regulation No. 28848, Annex 1, Article 1.5.2. Below are examples of labelling to be carried out when there is packaging larger and smaller than 125 ml not supplied to the public. The expression in the regulation for classifications related to this example is as follows: 1.5.2.1.1. Hazard statements and precautionary statements related to the hazard categories listed below may be omitted from the label elements specified in Article 19 of this Regulation under the following conditions: (a) the contents of the package do not exceed 125 ml; and (b) the substance can be classified as one or more of the following hazard categories; 3) Flammable liquids in Category 2 or 3; 11) Acute toxicity in Category 4 provided the substances or mixtures are not supplied to the public; 12) Skin irritation in Category 2; 17) Hazardous to the aquatic environment – Chronic in Category 1 or 2. In Regulation No. 28848, Annex 1, Article 1.5.2, no exceptional condition is specified for acute toxicity classification in packages smaller than 125 ml. Therefore, as in the example below, the hazard statement for acute toxicity category 4-H302 classification and the corresponding precautionary statements were not omitted from the label. This article has addressed the most basic topics regarding general chemical labelling. There may be many more criteria that determine labelling requirements. Therefore, the product supplier should consider conditions such as product type, packaging form and size, and determine whether it is subject to an official regulation under the scope of its relevant ministry. Those who prepare labels must be familiar with Regulation No. 28848 and its annexes. For this purpose, it would be a more appropriate approach for persons holding a safety data sheet preparer certificate from an accredited organization to carry out this work. It should not be forgotten that hazardous chemical labelling carried out in accordance with regulations is a preventive measure against harmful effects on humans and the environment and accidents in workplaces; at the same time it is a positive commercial contribution to the reputation and standing of supplier companies. Bülent Özdemir / Chemical Legislation Expert Manager / CRAD Çevre Risk Analiz Denetim ve Eğitim Hizm. A.Ş.