No. 2 January 2021

INDUSTRIAL NITROCELLULOSE

The new GHS classification.

Regulatory update for products that include the use of nitrocellulose in the production of varnishes and enamels.

The GHS (Globally Harmonised System of Classification and Labelling of Chemicals) for industrial nitrocellulose has been amended in Europe with the entry into force on 17 October 2020 of the 12th Adaptation to Technical and Scientific Progress.

Commission Regulation (EU)  2019/521 of 27 March 2019 (Official Journal of the European Union L86 of 28/03/2019) amends, for the purposes of adaptation to technical and scientific progress, EC Regulation no.  1272/2008 on the classification, labelling and packaging of substances and mixtures (CLP).

In particular, this adaptation amends some technical provisions and criteria of Annexes I, II, III, IV, V and VI of the CLP regulation to take into account the sixth and seventh revisions of the GHS.

The change only affects the GHS, and there is no change to the transport classification, which will remain classified in class 4.1 – Flammable Solids.  All the other national, regional and local regulations for industrial nitrocellulose remain unchanged and must be complied with.

The new GHS depends on the burning rate of the nitrocellulose product measured in the burning rate test for desensitised explosives, with categories assigned from 1 to 4. Category 1 is assigned to the highest burning rate and Category 4 to the lowest burning rate. The burning rate of nitrocellulose varies according to nitrogen content, viscosity and phlegmatizing agent.

The new UN GHS chapter 2.17 is based on the German regulation for desensitised explosives, since substances from the chemical industry exhibit very rapid combustion behaviour similar to products containing nitrocellulose, but which are not explosive.

Industrial nitrocellulose has been tested and classified according to these regulations.

The new GHS will not effect safety on the sites, operating conditions or risk management measures.

The information herewith given is based on our present knowledge. Any conclusion and recommendation are made without liability on our part. Buyers and users are advised to make their own assessment under their own conditions and for their own requirements.