Linking Seveso with the CLP environmental hazard categories

The Seveso Directive addresses environmental risks as well as risks to people's health and safety.

The Environment Agency (in England and Wales) and the Scottish Environment Protection Agency (in Scotland) lead Competent Authority work on the environmental aspects of Seveso.

Which environmental classifications are currently relevant to Seveso?

Under the current EU Directives on classifying dangerous substances and preparations (DSD/DPD) the following environmental classifications and Risk phrase combinations are relevant to Seveso:

• N: Dangerous for the environment: R50 "Very toxic to aquatic organisms"
• N: Dangerous for the environment: R50/53 "Very toxic to aquatic organisms.  May cause long term adverse effects in the aquatic environment"
• N: Dangerous for the environment R51/53 : "Toxic to aquatic organisms.  May cause long term adverse effects in the aquatic environment"

What are the new environmental categories in the CLP Regulation?

Three classification categories for substances hazardous to the aquatic environment are relevant to Seveso:

• Acute (short-term) aquatic hazard Category 1
• Chronic (long-term) aquatic hazard Category 1
• Chronic (long-term) aquatic hazard Category 2

What are the implications of the new CLP classifications?

It is possible to translate the current classifications that are relevant to Seveso into the new criteria in the CLP Regulation as follows:

• N: R50 becomes Aquatic Acute 1
• N: R50-53 becomes Aquatic Acute 1, Aquatic Chronic 1
• N: R51-53 becomes Aquatic Chronic 2

Further information is contained in:

• The ‘Environmental Hazards’ section (Page 35) of the The Technical Working Group Report on the Application of GHS substances classification criteria for the identification of Seveso establishments,

• Comparison between the EU and GHS criteria - Human health and the Environment

Will the introduction of 'M factors' make any difference?

When substances are classified under CLP as Aquatic Acute Category 1 Chronic Category 1, it is necessary to indicate an appropriate 'M-factor'.  This 'multiplying factor' gives an increased weight to substances which are very toxic for the aquatic environment when mixtures containing them are classified.  As a result it is possible that the number of classified mixtures in the future may increase.

The use of M-factors is not new - it came into force through the 2nd Adaptation to Technical Progress of the Dangerous Preparations Directive in January 2006.  However, while their use is not directly related to aligning Seveso with CLP, the classification of some mixtures under CLP (which were not previously classified under DPD) could bring some sites into the scope of Seveso.

(Note that all mixtures must be classified using CLP criteria from 1 June 2015.)

How you could help

The Competent Authority would like to know if the translation approach and/or the change in classification approach to mixtures could lead to any concerns with sites meeting the Seveso criteria, or any practical difficulties.