What does P391 mean?

What kind of precautionary statement is P391?

Response statements (P3xx) say what to do after an accident, spill, fire or exposure: first-aid steps, rinsing and washing, calling a doctor or a poison centre, choosing the extinguishing medium. They usually open with a situation such as IF IN EYES or IF INHALED.

Which hazards is it used for?

In the CLP Annex IV assignment table, P391 is assigned to the classes of these hazard statements:

• H400Very toxic to aquatic life.
• H410Very toxic to aquatic life with long lasting effects.
• H411Toxic to aquatic life with long lasting effects.

How many hazard statements is P391 assigned to?

In the CLP Annex IV assignment table, P391 is provided for the classes of 3 H statements in total: 3 environmental hazard statements. The lowest-numbered example is H400 and the highest-numbered is H411. Whether a mixture label carries this statement depends on those classes really applying to the mixture.

Neighbouring statements of the same kind

The statements closest in number to P391 in the response group:

• P380Evacuate area.
• P381In case of leakage, eliminate all ignition sources.
• P390Absorb spillage to prevent material damage.

How is P391 read?

The text of P391 is 2 words long. The text is a single instruction without options and is written as it appears in Annex IV.

Where is P391 written in the SDS?

In the SDS, P391 is written in Section 2.2 (label elements) with its code and the text "Collect spillage.". Being a response statement, it sits among the response lines. The statement should also agree with the accidental release measures in Section 6.

How does P391 appear on the label?

On the label P391 appears together with its text; under CLP Article 28(3) a label usually carries at most 6 precautionary statements. In the Chemoris selection method, response statements are considered in position 1. If the core statements exceed 6, Article 28(3) allows up to 8; when a combined statement is chosen, its individual parts are not repeated on the label. As P391 is on the list of precautionary statements of Annex IV, it can be used in current labels and SDSs; Chemoris writes it into the document only when the relevant response candidate is selected.

Which classes and which priority is P391 assigned to?

In the CLP Annex IV assignment table, P391 appears in 3 class/category entries (1 different H statements). Priority split: core (priority 1) in 3 entries. Of these entries, 0 carry the signal word “Danger”, 2 carry “Warning” and 1 need no signal word. The pictograms that most often accompany it: GHS09 (3).

The class families it appears in most often: Aquatic Chronic (2) and Aquatic Acute (1).

Classes that P391 is assigned to

The first 3 rows of 3 entries in the CLP Annex IV assignment table (by priority and hazard order):

Statements assigned together with P391

The precautionary statements that most often appear with P391 in the same class entries (with entry count):

• P273Avoid release to the environment. (3)
• P501Dispose of contents/container to … (3)

Where does P391 stand in the response group?

P391 is number 52 of the 82 statements in the P3xx group. The group holds 30 combined and 11 withdrawn statements and 46 single valid statements. Combined statements merge several situations on one line; withdrawn statements are replaced by their current equivalents.

Which SDS section does P391 feed?

Because of its number and its response kind, P391 relates to Section 6 Accidental release of the SDS; in Section 2.2 it is written with its code and text. Statements in the same number range feed the same section.

Checklist when writing P391

• P391 should agree with Section 6; in Section 2.2 it is written with its code and text.
• The text is 2 words long; if the label space is narrow, choosing a combined statement can save room.

Official EU wording of P391 in other languages

When a product is exported to the EU, the SDS and label are expected in the official language of the Member State where it is placed on the market (REACH Article 31(5)). The table gives the official wording of P391 from the CLP Annex III/IV language versions published in the Official Journal of the European Union. Source: EUR-Lex CELEX 02008R1272-20260701.

Next steps

To read a statement like P391 correctly on a label and in an SDS, see the guide How to read H and P codes; to pick the class and prepare the label automatically, use the free label tool.

Where does it appear in the safety data sheet?

Precautionary statements are given with their code and full text in Section 2.2 (label elements) of the safety data sheet. Alternatives separated by a slash or in square brackets (e.g. gloves/protective clothing) are narrowed down to suit the product.

Frequently asked questions