Hazmat 101 News - November 2007

The Globally Harmonized System for Hazard Communication is Coming--An Overview

By Daniel Levine, CHMM

Chemicals are essential to our quality of life but may have properties that pose dangers to human health and the environment. It is critical that there is information available to understand the dangers of chemicals. Chemical hazard communication standards from country to country vary from well-prescribed to non-existent. In order to improve safety across countries and remove barriers to global trade,  the United Nations was asked to develop the Globally Harmonized System or GHS for hazard classification and labeling. In this article we will give you a quick overview of the GHS.

The GHS was formally adopted by the UN's Economic and Social Council in July of 2003. The culmination of 10 years of work and negotiations, GHS establishes a single worldwide definition for the various physical, health and environmental hazard end points for chemical substances and mixtures of chemical substances. It also establishes a common methodology for communicating these hazards in various regulatory venues.

It will be useful to all types of audiences, including  employers, workers, consumers, transport workers, and emergency responders.

The system finally establishes common definitions of such common hazard end-points a "flammable" and "toxic". Right now, there are multiple definitions of flammable around the world, but more perplexing, there are different definitions of flammable within the regulations of the United States. GHS will end the confusion.

The table below shows the definitions of flammability just within the U.S. (let alone Canada, Europe and the Pacific Rim).

 

Under the GHS, there will be 4 commonly defined categories for flammable liquids.

The definitions of toxic (this time including Canada but not Europe and the rest of the world) are currently these:

Will be replaced with this classification scheme:

The following tables show the physical and health hazard categories that have been defined:

Physical Hazards
Explosives Flammable gases Substances which, in contact with water, emit flammable gases
Flammable aerosols Flammable liquids Oxidizing liquids
Gases under pressure Flammable solids Oxidizing solids
Self-heating substances & mixtures Self-reactive substances & mixtures Oxidizing gases
Pyrophoric liquids Pyrophoric solids Organic peroxides
Corrosive to metals    
Health Hazards
Acute Toxicity Skin corrosion/irritation Specific target organ system toxicity - single exposure
Serious eye damage / eye irritation Respiratory and skin sensitization Specific target organ system toxicity - repeated exposure
Germ cell mutagenicity Carcinogenicity Hazardous to the aquatic environment
Reproductive toxicity Respiratory tract irritation & narcotic effects Aspiration hazard

Each organization will be free to use the categories that it normally is responsible for. This is the building block principle. For example, while irritants and carcinogens will have common definitions, the U.S. DOT will not regulate these substances and they are not within the current mandate of the DOT. Likewise, OSHA may or may not regulate oral toxicity category 4 but would definitely not regulate category 5 as it is beyond the scope of its current hazard communication regulations.

Furthermore, labels will change as well. All containers will be required to display symbols that describe the general class of hazard associated with the contents. The exceptions would be if a transport (DOT) label for the same hazard were already on the container. Thus a drum of flammable liquid would show the standard DOT flammable label.

But if the material were also an irritant and a carcinogen, the following symbols would also appear on the drum:

Standard phrases to describe the hazards are proscribed and as of now, standard precautionary phrases are recommended but not mandatory.

Materials Safety Data Sheets will also change. 

First thing is that the word "Material" will be dropped and the sheets will simply be called "Safety Data Sheets" or SDSs. The ANSI/ISSO 16 section format will be mandatory but with one significant change. Section 2, which used to list the hazardous ingredients, will swap positions with Section 3 which describes the potential hazards of the material or mixture. This way, the hazards will appear first. The list of ingredients will follow but clearly, the nature of the hazards is given priority.

While the earliest U.S. agency target for implementation is officially 2008 (EPA), the U.S. DOT has been slowly implementing some changes to keep up with the UN Committee of Experts. OSHA has published an Advanced Notice of Proposed Rulemaking but not a proposed rule and the CPSC has yet to publish any rulemaking. Full implementation is still years away but in Japan, implementation for certain hazardous chemicals began on January 1, 2007.

Conclusion
For now, you can get the official GHS documentation at the following web site: http://www.unece.org/trans/danger/publi/ghs/ghs_rev00/00files_e.html 

About the Author
Daniel Levine

Daniel Levine is president of Product Safety Solutions, a consulting firm providing services in product hazard communication, product stewardship and chemical regulatory compliance. Prior to starting Product Safety Solutions in 1998, he was Director of Product Safety and Integrity for AlliedSignal Inc (now Honeywell International). He has 38 years of experience in chemical manufacturing and product safety. He is a past president and current web committee chair of the Society for Chemical Hazard Communication and is a member of the executive board of the New Jersey Chapter of the Academy of Certified Hazardous Materials Managers and a member of the national Academy's professional development committee. Web site: www.productsafetysolutions.com