DanGoods
Training & Consultancy Limited
86 New Forest Drive, Brockenhurst, Hampshire SO42 7QW
Tel: 0702 097 3816 Fax: 0702 097 3762
E-mail: Info@DanGoods.co.uk Web:www.DanGoods.co.uk
VAT Registered number: 731 6338 44
BRIEFING
Tactile Warning of Danger (TWD)
Introduction
Tactile Warning of Danger (TWD) is a sensory device required to be present on the
immediate packaging (e.g. bottle or tube) of certain dangerous/hazardous chemicals
supplied to the general public to alert visually handicapped, general public users, of
the fact that the receptacle contains a dangerous/hazardous chemical.
Regulatory Basis in European Community
In the European Union (EU) the requirement to have a TWD on the immediate
packaging of certain dangerous/hazardous chemicals is found in:
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For substances in the Regulation (EC) No 1272/2008 on classification,
labelling and packaging of substances and mixtures (known in short as
“CLP”)
For preparations (now often known as mixtures) until 1 June 2015 in the
1999/45/EC Dangerous Preparations Directive (DPD)
For mixtures (formerly known as preparations) from 1June 2015 latest,
or earlier if voluntary decision is taken to supply classified, labelled and
packaged in accordance with CLP before 1 June 2015
A TWD is required for substances, and any mixture supplied that is classified,
labelled and packaged to CLP, if the substance or mixture is supplied to the
general public and is:
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Acute toxicity Categories 1, 2, 3 or 4
Skin Corrosion Category 1
Germ cell Mutagenicity Category 2 (note Category 1 are prohibited)
Registered in England & Wales
Office: Unit 7 Hayters Court, Griggs Lane, BROCKENHURST SO42 7PG Registered number 3812168
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Carcinogenicity Category 2 (note Category 1 are prohibited)
Reproductive Toxicity Category 2 (note Category 1 are prohibited)
Respiratory Sensitiser (Category 1)
Systematic Target Organ Toxicity – Single Exposure Category 1 or 2
Systematic Target Organ Toxicity – Repeated Exposure Category 1 or 2
Aspiration Hazard Category 1
Flammable Gases Category 1 or 2*
Flammable Liquids Category 1 or 2*
Flammable Solids Category 1or 2
* Note: under CLP aerosols have their own flammability classifications and
these do not attract the TWD requirements.
Note: The TWD is required whatever the capacity of the packaging. It is
understood that this only applies to the packaging immediately holding the
chemical, and not to any higher layers of packaging.
A TWD is required for preparations that are not yet classified, labelled and
packaged in accordance with CLP but are classifiable under the DPD with the
following INDICATIONS OF DANGER (not same as symbol letter allocation):
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Very toxic (including any such aerosol preparation)
Toxic (including any such aerosol preparation)
Harmful (including any such aerosol preparation)
Corrosive (including any such aerosol preparation)
Extremely flammable (excluding aerosol preparations)
Highly Flammable (excluding aerosol preparations)
TWD Requirement
CLP and DPP (via Annex IX of the DSD) simply requires that the TWD shall comply
with the standard EN ISO 11683, as amended.
Standard 11683 specifies that the TWD ‘symbol’ is normally a raised frame
equilateral triangle with sharp as possible corners and side length of 18mm, frame
width of 1.7 mm and frame height of between 0.25 and 0.5 mm.
Three reduced size/alternate symbols are specified:
 The 9 mm TWD
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 The 3 dot symbol for use where the 9mm symbol can’t be used (e.g. for
use on collapsible tubes and cartridges of adhesives and sealants )
 The 3mm filled symbol; for where the 3 dot symbol can’t be used (e.g.
for very small tubes of adhesives or sealants)
The symbol must be placed according to location rules, though these are often quite
flexible. It should be noted that the requirement only applies to the receptacle
immediately containing the chemical, and that application outwards through the layers
is not required.
There is no specification for colour (as they are for the visually handicapped), so the
TWD can be applied by clear sticker to an already printed area, though any legibility
issues of cautionary text or readability of EAN bar codes must not be compromised. .
Notes: For aerosols if required, which would be rare for adhesives and sealants, the
TWD is to be placed on the actuator of the release device.
For containers of combustible gas other issues may apply. Consult the standard.
Prepared by
Desmond WAIGHT
DanGoods Training & Consultancy Ltd
Revised June 2013 – replaces 2006 version.
END
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