p-benzoquinone dioxime

GHS

General Information

Name:

p-benzoquinone dioxime - transport packaged solid

Implementation:

EU

Type of classification:

self-classification

Remarks:

The approach to Classification and Labelling for the substance is described below due to the following: there are anomalies described in detail in the UN Transport of Dangerous Goods: MTC (2015 as amended) and the ECHA Guidance on Application on the CLP Criteria, section 5.1.5.1 (v5.0, July 2017), concerning ‘deficiencies’ in the hazard communication under GHS.

(1) The packaged substance meets the classification criteria under Regulation (EC) No 1272/2008 for explosives – Division 1.4 compatibility group C : H204: Fire or projection hazard.
Packaging types: (i) 34-gallon fibre drum (1G), net weight 45.4 kg ; (ii) 10-gallon fibreboard drum (1G), net weight 15 kg ; (iii) 5-gallon fibreboard drum (1G), net weight 4 kg ; (iv) 5-gallon PE pails removable head (2H1) inserted in fibreboard box (4G), net weight of 5-gallon was about 8 kg ; (v) 4 PE gallon jerricans (3H2) inserted in fibreboard box (4C), net weight of each gallon ranged between 1.4 - 1.7 kg ; (vi) plastic jerricans (3H1) with removable head and a volume of 20 1/5 gallon (inner packaging). Each plastic jerrican was inserted in a fibreboard box (4G) (outer packaging), net weight was about 8 kg

(2) The unpackaged substance & repackaged in non-original container has the potential to meet the classification criteria under Regulation (EC) No 1272/2008 for explosives – Division 1.1: H201: Explosive; mass explosion hazard ; when inappropriately packaged or when re-packaged (not in original packaging containers) due to ‘Risk of explosion if heated under confinement’.

The risk to users of the substance when un-packaged or re-packaged substance (not in original packaging) is covered by the automatic application of : CLP Regulation (EC) 1272/2008: Note 1 to Table 2.1.2 in Annex 1 – section 2.1.3 which states:

Unpackaged explosives or explosives repacked in packaging other than the original or similar packaging shall include all of the following label elements
(a) the pictogram: exploding bomb;
(b) the signal word: ‘Danger’; and
(c) the hazard statement: ‘explosive; mass explosion hazard’

This is to ensure that substances which may technically be ‘inadequately covered’ by the classification criteria per se : due to ‘packaging dependence’ will remain covered and the risks of the substance which is unpackaged/re-packaged (non-original container) due to ‘Risk of explosion if heated under confinement’ are communicated. Refer to ECHA Guidance on the CLP criteria (2017) – pages 104-107 for further information.

Other comments:
The unpackaged substance was demonstrated as meeting the GHS Flammable Solids: category 1 within a test consistent with the UN MTC Method N.1: Burning rate test which resulted in a GHS Transport Classification Flammable Solids: Division 4.1: Packing Group II. The flame passed the wetted zone. Although this hazard criteria is not applicable, due to the application of the GHS explosives – Division 1.4 compatibility group C, classification, it should be acknowledged (even if GHS Explosive Division 1.4, is applied).

References:
1. REACH Regulation (EC) 1907/2006, Annex VII, section 7.11
2. CLP Regulation (EC) 1272/2008, Annex I, section 1 and 2
3. UN Transport of Dangerous Goods Manual of Tests and Criteria, Seventh Edition (2019)
4. ECHA Guidance on Application on the CLP Criteria, section 2.1 (v5.0, July 2017)
5. ECHA Guidance on Information Requirements and Chemical Safety Assessment (Chapter R.7a: Endpoint Specific Guidance, July 2017)

Related composition

Related composition:

1,4-benzoquinone dioxime

1,4-benzoquinone dioxime

Classification

Physical hazards

Explosives

Hazard category:

Expl. Div. 1.4

Hazard statement:

H204: Fire or projection hazard.

Flammable gases and chemically unstable gases

Reason for no classification:

data conclusive but not sufficient for classification

Aerosols

Reason for no classification:

data conclusive but not sufficient for classification

Reason for no classification:

hazard class not assessed

Oxidising gases

Reason for no classification:

data conclusive but not sufficient for classification

Gases under pressure

Reason for no classification:

data conclusive but not sufficient for classification

Flammable liquids

Reason for no classification:

data conclusive but not sufficient for classification

Flammable solids

Reason for no classification:

hazard class not applicable

Self-reactive substances and mixtures

Reason for no classification:

data conclusive but not sufficient for classification

Pyrophoric liquids

Reason for no classification:

data conclusive but not sufficient for classification

Pyrophoric solids

Reason for no classification:

data conclusive but not sufficient for classification

Self-heating substances and mixtures

Reason for no classification:

data conclusive but not sufficient for classification

Substances and mixtures which in contact with water emit flammable gases

Reason for no classification:

data conclusive but not sufficient for classification

Oxidising liquids

Reason for no classification:

data conclusive but not sufficient for classification

Oxidising solids

Reason for no classification:

data conclusive but not sufficient for classification

Organic peroxides

Reason for no classification:

data conclusive but not sufficient for classification

Corrosive to metals

Reason for no classification:

data conclusive but not sufficient for classification

Desensitized explosives

Reason for no classification:

data conclusive but not sufficient for classification

Health hazards

Acute toxicity - oral

Hazard category:

Acute Tox. 4

Hazard statement:

H302: Harmful if swallowed.

Acute toxicity - dermal

Reason for no classification:

data lacking

Acute toxicity - inhalation

Reason for no classification:

data conclusive but not sufficient for classification

Skin corrosion / irritation

Reason for no classification:

data conclusive but not sufficient for classification

Serious eye damage / eye irritation

Hazard category:

Eye Irrit. 2

Hazard statement:

H319: Causes serious eye irritation.

Respiratory sensitisation

Reason for no classification:

data lacking

Skin sensitisation

Hazard category:

Skin Sens. 1A

Hazard statement:

H317: May cause an allergic skin reaction.

Aspiration hazard

Reason for no classification:

data lacking

Reproductive toxicity

Reason for no classification:

data lacking

Effects on or via lactation

Reason for no classification:

data lacking

Germ cell mutagenicity

Hazard category:

Muta. 2

Hazard statement:

H341: Suspected of causing genetic defects <state route of exposure if it is conclusively proven that no other routes of exposure cause the hazard>.

Carcinogenicity

Hazard category:

Carc. 2

Hazard statement:

H351: Suspected of causing cancer <state route of exposure if it is conclusively proven that no other routs of exposure cause the hazard>.

1. Specific target organ toxicity - single (STOT-SE)

Reason for no classification:

data conclusive but not sufficient for classification

1. Specific target organ toxicity - repeated (STOT-RE)

Reason for no classification:

data conclusive but not sufficient for classification

Environmental hazards

Hazardous to the aquatic environment (acute / short-term)

Reason for no classification:

data lacking

Hazardous to the aquatic environment (long-term)

Hazard category:

Aquatic Chronic 2

Hazard statement:

H411: Toxic to aquatic life with long lasting effects.

Hazardous to the ozone layer

Reason for no classification:

data conclusive but not sufficient for classification

Labelling

Signal word:

Warning

Hazard pictogram

GHS01: exploding bomb

GHS07: exclamation mark

GHS08: health hazard

GHS09: environment

Hazard statements

H204: Fire or projection hazard.

H302: Harmful if swallowed.

H317: May cause an allergic skin reaction.

H319: Causes serious eye irritation.

H341: Suspected of causing genetic defects <state route of exposure if it is conclusively proven that no other routes of exposure cause the hazard>.

H351: Suspected of causing cancer <state route of exposure if it is conclusively proven that no other routs of exposure cause the hazard>.

H411: Toxic to aquatic life with long lasting effects.

Precautionary statements

P210: Keep away from heat, hot surfaces, sparks, open flames and other ignition sources. No smoking.

P234: Keep only in original packaging.

P272: Contaminated work clothing should not be allowed out of the workplace.

P280: Wear protective gloves/protective clothing/eye protection/face protection/hearing protection/...

P273: Avoid release to the environment.

P370+P372+P380+P373: In case of fire: Explosion risk. Evacuate area. DO NOT fight fire when fire reaches explosives.

P391: Collect spillage.

P501: Dispose of contents/container to ...