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Flammable Liquids

INTRODUCTION


The main purpose of this Technical Bulletin is to clarify the position as regards the classification of flammable liquids arising from the phased introduction of European Regulation (EC) 1272/2008 on Classification, Labelling and Packaging of Substances and Mixtures (CLP Regulations), adopting in the EU the Globally Harmonised System (GHS), and to affirm RiskSTOP risk control strategy.


The CLP Regulations replaced the CHIP Regulations on 1 June 2015. There were certain limited circumstances where CHIP labelling and packaging of mixtures (formerly preparations) could remain on the market after 1 June 2015.  Where a mixture had already been classified, labelled and packaged according to CHIP, and placed on the market (‘on-the-shelves’) before 1 June 2015, it did not have to be recalled for re-labelling and re-packaging.  This derogation was available until 1 June 2017. 


This Technical Bulletin should be read in conjunction with TB 21 (DSEAR).

 

CLP REGULATIONS - CATEGORISATION

The following table sets out the criteria and categorisation applicable to the CLP and CHIP (historical) Regulations. 

 

For RiskSTOP purposes, both currently and for the foreseeable future, liquids falling within Categories 1 & 2 are to be described as “highly flammable” and those within Category 3 as “flammable”.


RSG RISK CONTROL STRATEGY


RSG risk control strategy concerning the storage and use of highly flammable and flammable liquids is firmly based on the following RISCAuthority publications:


  • RC55: Recommendations for fire safety in the storage, handling and use of flammable and highly flammable liquids (general guidance regarding small volumes of flammable and highly flammable liquids in the workplace).

  • RC56: Recommendations for fire safety in the storage, handling and use of highly flammable and flammable liquids: storage in containers other than external fixed tanks.

  • RC57: Recommendations for fire safety in the storage, handling and use of highly flammable and flammable liquids: storage in external fixed tanks.


Consultants will note that these documents continue to employ a benchmark flashpoint of 32⁰C when defining highly flammable liquids and are therefore in conflict with the CHIP Regulations (as referenced in DSEAR) and the CLP Regulations (Classification, labelling and packaging of substances and mixtures), which adopt flash points of 21⁰C and 23⁰C respectively. This is recognised by the RISCAuthority who intend to review their position once the migration over to the CLP Regulations has been completed.


When assessing the hazards presented by flammable liquids and the risk control considerations that apply, particular recognition should be given to the following:


  • The benchmark flash point of 23⁰C should not be considered as mandatory when considering the provision of enhanced fire safety measures such as earth bonding, hazardous area zoning and equipment protection under the ATEX Directive, use of safety containers, etc., normally reserved for highly flammable liquids. There is no reason why, for a specific case, a higher benchmark of up to 32⁰C (pre DSEAR) should not be employed where determined by a risk assessment. For example, this could be applied to a poorly insulated building where ambient summer temperatures in the workplace regularly exceed the 23⁰C baseline. In circumstances where flammable liquids are heated as part of the process, special considerations would apply. 

  • At the opposite end of the hazard spectrum, the above RC documents recognise that whilst applying to all flammable and highly flammable liquids, some of the recommendations can under certain conditions be relaxed, where liquids with higher flash points are concerned. The extent to which such relaxations apply may be one of the outcomes of the DSEAR risk assessment.



    As an example, this may apply to the well managed storage of moderate quantities of flammable liquids with flash points considerably in excess of 23⁰C, contained within retail or warehouse premises, which may be considered to present no inception hazard, and no greater contributory hazard than the majority of other commodities stored. In such cases the Consultant should make a judgement based on the prevailing circumstances and with reference to the documented DSEAR risk assessment.


Post Brexit, changes in the way the CLP Regulations are administered are being made under the auspices of the HSE. 23°C


In the event of any queries or concerns regarding flammable liquids relative to a specific case, Consultants should contact the Technical Helpline.

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