GHS: a New Paradigm for Global Hazard Communication

1
GHS  a New Paradigm for Global Hazard
Communication
2
?

• Globally
• Harmonized
• System
• of Classification and Labelling of Chemicals

3
?

• Global

4
APEC Target Implement by 2006
Global?

• New Zealand
• Current legislation allegedly GHS based, but
  differs in key ways
• 2500 substances classified
• Accepts GHS MSDS
• Japan
• Has started publishing substance classifications
• No draft law, but compliance required by 1 Dec
  2006!
• JIS Standards for MSDS, Label
• Mexico
• APEC member, but has said they will not start
  before other key economies

• P.R. China
• Guideline has been issued but no specific
  implementation date announced
• Indonesia
• Legislation translated, but unlikely to start as
  a leader
• Will accept GHS MSDS
• APEC Members expected to follow the key actors
• Brunei Darussalam, Chile, Hong Kong, Papua New
  Guinea, Peru, Philippines, Russian Federation,
  Taiwan, Vietnam

see http//www.safe.nite.go.jp/ghs/list.html
5
UN Target 2008
Global?

• Singapore
• Task force actively pursuing roadmap for
  implementation in 2007
• Thailand
• Two phase plan
• 2007 substances--physical hazards and urgent
  health and environmental hazards
• 2008 remaining hazards for substances mixtures
• Canada
• Target implementation in 2008

• Australia, Malaysia
• Intends to amend regulations in 2006 for
  implementation in 2008
• South Africa
• Will follow other key actors
• Korea
• Voluntary legislation expected shortly
• Enforcement to start 2008
• UNITAR Trained, expected to follow key actors
• Gambia, Nigeria, Senegal

6
Target 2008 ?
Global?

• USA
• Aug Dec 2005 targets for Advanced Notice of
  Proposed Rulemaking missed
• Apr 24 ANPRM target May 2006
• 7 June Foulke ANPRM is prepared, detailing
  how OSHA expects GHS to affect current hazcom
• Plans also at EPA, DOT
• No date commitment made yet,expected to attempt
  to meet UN Goal of 2008

• EU
• With REACh
• Long phase-in expected to result in enforcement
  2010 (substances)/2014 (mixtures)
• Other countries
• India, Pakistan no plans announced

7
?

• Harmonized

8
Building Blocks
Harmonized?

• Targeted to all hazardous chemicals
• No Lists of officially classified substances
  proposed
• Nonetheless Precedent in New Zealand Japan
• Mode of Communication may vary
• MSDS
• Labels
• Targeted to ALL users
• Workers, Industrial and Professional
• Transportation Sector
• Emergency Responders
• Consumer

9
Building Blocks

• Each Country may select the building blocks as
  they wish
• It is not required to select all building blocks
  nor all categories of hazards
• Allowance is made for local authorities to adopt
  additional hazards not addressed by GHS
• If a country selects a building block, it should
  be applied as it is defined in GHS
• Blocks may not be skipped

10
Building Blocks
Harmonized?

• What is a building block?
• If you choose to recognize a hazard class, must
  all categories (1 5) also be adopted?
• If you designate labelling as the method of
  communication, must all label elements be
  required?
• If MSDS, must all chapters be required?

11
Harmonized?
Harmonized?
12
Advantages
Harmonized?

• Must learn only one system of classification
• Local variation will depend upon which hazards
  and categories are regulated locally
• Symbols will be uniform globally so worker
  comprehension is supported
• Number of label and MSDS formats will certainly
  be reduced, helping to minimize non-tariff
  barriers to trade

13
?

• System

14
GHS The Purple Book (gt 500 pages)
System
15
Classification
System

• Testing is generally not required, except some
  physical hazards
• Physical hazards
• Largely align with the existing Transport of
  Dangerous Goods System (Orange Book)
• Health Hazards
• Increase in classified substances and mixtures
  expected over all other known systems currently
  in existence
• Environmental Hazards
• Based on EU system, but also an expansion over
  regulatory systems currently practiced worldwide

16
Classification
System

• Body of classified substances and mixtures
  expected to expand significantly under GHS
• Lowest category should be applied only for
  consumer and distributed applications
• Caffein Danger Toxic if Swallowed
• LD50279 ? Acutely Toxic Cat. 3

Caution HOT!
17
Classification
System

• Mixtures
• Classify based on testing, if available
• Batching is explicitly allowed
• Bridging Principles
• Can classify by the same category as the main
  substance if it is diluted with non-hazardous
  substance
• Substance in highest category can be classified
  still in highest category if concentrated
• Mixture of ingredients in same category can be
  classified as still in that category (unless
  additive effects suspected)
• Characteristics of mixtures
• e.g. pH ?2 or ?11.5 is corrosive

18
Classification
System

• Mixtures Calculation Methods
• Usually over-conservative not always logical
• LACK of toxicity data may lead to severe
  over-classification of mixtures in the current
  methods
• Tox data is mainly lacking for less toxic
  ingredients, so summing over the known
  ingredients weights the toxic components too
  highly
• Example

19
Label Elements
System

• Signal Word
• DANGER or WARNING
• Hazard Statements
• Precautionary Statements and Pictograms
• Product Identifiers (more on next 2 slides)
• Supplier identification
• Name, address, telephone number of manufacturer
  or supplier
• Supplementary information
• At local discretion, but should not conflict or
  undermine GHS

20
Label Elements Product Identifiers
System

• Name matching SDS
• Chemical identities (more on next slide)
• Confidential Business Information (CBI)
  protection may apply as specified by local
  authorities
• UN proper shipping name
• If the product is subject to transport of
  dangerous goods rules

21
Label Elements Product Identifiers
System

• Chemical identity for substances
• Chemicals contained which contribute to specific
  hazards identified on the label
• Acute toxicity
• Skin corrosion
• Severe eye damage
• Carcinogenic, mutagenic, reprotoxic effects
• Sensitizing (skin or respiratory)
• Specific Target Organ Systemic Toxicity (STOST)
• OR
• Chemicals contained which contribute to ANY
  hazards identified on the label
• OR
• Identify chemicals in SDS rather than label if
  appropriate to audience (e.g. in workplace)

22
Label Pictographs New in GHS
System

• Flammable
• Oxidizer
• Toxic
• Corrosive

• Health
• Hazard
• Harmful
• Environment
• Hazard

? Plus Orange Book (Transport) Labels if the
transport label is applied, the GHS diamond is
not added.
23
Label Element Hierarchy
System

• IF NOT
• IF NOT
• Where ! applies due to skin or eye irritation
• IF NOT
• Where ! Applies due to respiratory sensitization
  or due to skin or eye irritation

• IF DANGER NOT WARNING
• ALL of the applicable Hazard Statements must be
  applied no hierarchy or limit controls their
  proliferation
• There is an example layout but NO required format
• GHS elements should be grouped together in one
  part

24
GHS Classification and Label Elements
System

• Please note that certain hazard building blocks
  are not described in detail in the following as
  they are less common cases
• Aerosols
• Gases under Pressure
• Organic Peroxides
• STOST guidelines are given but expert
  determination is key

STOST Specific Target Organ Systematic Toxicity
25
GHS Explosive
System
26
GHS Explosive
System
27
GHS Oxidizer
System
28
GHS Oxidizer
System
29
GHS Flammable
System
30
GHS Flammable
System
31
GHS Flammable
System
32
GHS Substances which release flammable gas in
contact with water
System
33
GHS Self-Reactive
System
34
GHS Self-Reactive
System
35
GHS Self-Heating
System
36
GHS Self-Heating
System
37
GHS Acute Toxicity Oral
System
38
GHS Acute Toxicity Oral
System
39
GHS Acute Toxicity Dermal
System
40
GHS Acute Toxicity Dermal
System
41
GHS Acute Toxicity Dust/Mist
System
42
GHS Acute Toxicity Gas/Vapor
System
43
GHS Acute Toxicity
System
44
GHS Corrosive to Skin
System
45
GHS Irritating to Skin
System
46
GHS Skin Corrosion or Irritation
System
47
GHS Irritating to Eyes
System
48
GHS Eye Irritant
System
49
Aspiration Hazard
System
50
GHS Aspiration Toxicity
System
51
GHS Sensitizer
System
52
GHS Sensitizer
System
53
GHS Carcinogen
System
54
GHS Carcinogen
System
55
GHS Mutagen
System
56
GHS Germ Cell Mutagen
System
57
GHS Reproductive Toxin
System
58
GHS Reproductive Toxicity
System
59
GHS STOST-Single Exposure
System
60
GHS STOST- Repeated Exposure
System
61
GHS Acute Toxicity - Lung
System
62
GHS Irritating to Respiratory
System
63
GHS Aquatic Toxicity
System
64
GHS Acute Aquatic Toxicity
System
65
GHS Chronic Aquatic Toxicity
System
66
GHS Other Env Toxicity
System
67
Attention Corollary Effects!
System

• Example
• SEVESO II law in Europe
• The thresholds for T are 10 times lower than T
• Oral toxicity example EU versus GHS

68
Major Differences with US OSHA HCS
Comparing OSHA and GHS

• Published by OSHA
• http//www.osha.gov/dsg/hazcom/docs/GHSOSHACompari
  son.pdf
• Less specificity of audience
• But GHS supports local authority specifying
  building blocks appropriate to specific
  audiences, such as laboratories, sealed
  containers, distributors
• GHS associates specific test methods with the
  hazard determination and requires testing for
  some physical hazards, where testing is not
  required by HCS
• but these are derived from transport laws so
  should not cause a large testing burden

HCS Hazard Communication Standard,
29CFR19101200
69
Major Differences with US OSHA HCS
Comparing OSHA and GHS

• Harmonization of IARC, NTP and OSHA CMR
  conclusions needs to be better defined
• Evaluation of Mixtures
• Calculation method differs from HCS and is closer
  to the concepts in use in the EU
• Use of own testing data for CMR in mixtures is
  accepted only case-by-case in spite of hierarchy
  for using test data on mixtures before
  calculation method

70
Major Differences with US OSHA HCS
Comparing OSHA and GHS

• GHS Labels
• Required pictograms, signal words
• Specified hazard statements must be used
• OSHA implies that they will use local competent
  authority perogative to avoid that the chemical
  contents must be named on the workplace label
• Substantially less performance related info on
  label, user referred to SDS instead for fire,
  spill and other instructions
• Flexibility for workplace labelling is retained
  in GHS

71
Major Differences with US OSHA HCS
Comparing OSHA and GHS

• GHS MSDS
• 1 Recommended use and restrictions on use
• 2 Hazards must follow GHS
• 3 report components at concentration cut-off
  for classification rather than HCS standard
  1/0.1
• 4 symptoms and effects described here
• 5,6 more emphasis on PPE for fires, spills
• 7 more focus on incompatibilities for storage
• 8 no specification of repair maintenance
  scenario
• 12, 13, 14 no requirements in HCS (EPA, DOT
  requirements)
• 10,16 very similar in both systems

72
Major Differences with US OSHA HCS
Comparing OSHA and GHS

• GHS MSDS 9 18 properties MUST be listed

• Appearance
• Odor
• Odor threshold
• pH
• Melting point/freezing point
• Initial boiling point and boiling range
• Flash point
• Evaporation rate
• Flammability (solid gas)
• Upper/lower flammability or explosive limits

• Vapor pressure
• Vapor density
• Relative density sp. gravity
• Solubility(ies) in water
• Partition coefficient n-octanol/water
• Auto-ignition temperature
• Decomposition temperature
• Viscosity
• Others may be included

Underlined specified in OSHA Form 174
73
Major Differences with US OSHA HCS
Comparing OSHA and GHS

• GHS MSDS 11 10 hazards MUST be listed

• Acute Toxicity
• Skin corrosion/irritation
• Serious eye damage/irritation
• Respiratory or skin sensitization
• Germ cell mutagenicity
• Carcinogenicity

• Reproductive toxicity
• STOST-single exposure
• STOST-repeated exposure
• Aspiration hazard

STOST Specific Target Organ Systematic Toxicity