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Title: Hazard Communication (HazComm2012) and the Globally Harmonized System (GHS)


1
Hazard Communication (HazComm2012) and the
Globally Harmonized System (GHS)
  • Mark Banden
  • Compliance Assistance Specialist
  • OSHA, Kansas City Area Office

2
Plan For the DayHazard Communication (HazComm
2012) and the Globally Harmonized System (GHS)  
  • Brief overview of the GHS
  • Benefits of revising the Hazard Communication
    Standard to adopt the GHS
  • Overview of some major changes to the HCS
  • Detailed Side-By-Side Review of Changes
  • Employee Training Program Example
  • References

3
Globally Harmonized System of Classification and
Labeling of Chemical - GHS
  • An Internationally common, coherent approach to
    classifying and communicating chemical hazards

4
What is GHS?
  • UN system developed to standardize the
    classification of chemicals and communication of
    hazards.
  • Revised every 2 years. Also known as the Purple
    Book. GHS (Rev.3) (2009) UNECE.
  • Already adopted in Europe and many other
    countries (China, Japan, New Zealand, Brazil,
    etc.).
  • GHS framework uses a building block approach
  • countries implement standardized elements they
    want
  • still have minor variations, but much less than
    in the past
  • Intended to facilitate international trade and
    improve the quality and consistency of hazard
    information provided.

5
GHS
  • Harmonizes classification, Safety Data Sheets
    (SDS) and labeling
  • Not a model regulation contains criteria and
    text
  • Specification versus Performance Oriented
    Approach
  • Created as a building-block approach
  • Each competent authority adopts those provisions
    applicable to sphere of regulation or need
  • Covers physical, health and environmental hazards
  • OSHA Standard Maintains current exceptions to
    coverage
  • Biological Agents
  • Radioactive elements
  • Consumer Products
  • Hazardous Waste
  • Etc..

6
OSHA and the GHS
  • OSHAs 1983 final HCS included recognition of the
    importance of international harmonization of such
    requirements, and a commitment to work towards an
    international approach
  • The Agency
  • Supported adoption of the international mandate
    to develop the GHS
  • Helped to negotiate the provisions of the GHS
    and
  • Leads the current US delegation to the United
    Nations Committee and Subcommittee on the GHS

7
ModifiedHazard Communication Standard(HazComm
2012)
8
Rulemaking History
  • OSHA published an advance notice of proposed
    rulemaking (ANPR) on September 12, 2006
  • The ANPR described OSHAs plan to apply the GHS
    to the HCS comments were received from over 100
    respondents
  • OSHA published a notice of proposed rulemaking on
    September 29, 2009, that provided a preamble
    explanation, as well as the text of the proposed
    modifications

9
Rulemaking History, cont.
  • The NPRM established a 90-day period for written
    comments
  • Public hearings were convened in Washington, DC,
    and Pittsburgh, Pennsylvania, to receive oral
    testimony
  • A period for post-hearing comments and briefs was
    established by the Administrative Law Judge
  • When the public record was completed, OSHA
    prepared the final rule based on the record,
    along with various analyses required for such
    standards
  • The final rule was published in the Federal
    Register on March 26, 2012 (77 FR 17574 17896)
  • The rule will be in effect 60 days later May 25,
    2012

10
Site visits Stakeholder meetings RFI or ANPR
SBREFA
Public Comment
Implementation
11
Why Adopt the GHS?
  • The primary purpose of the HCS is to reduce
    chemical source illnesses and injuries
  • Since the HCS was promulgated in 1983, acute
    illnesses and injuries from chemicals have
    decreased 42
  • However, there is still a critical need for
    effective information to protect exposed workers
    from chemicalsparticularly from chronic effects

12
Why Adopt the GHS, cont.
  • A key part of the new approach is increased
    comprehensibility due to the standardized or
    harmonized approach to information dissemination
  • Standardized Information includes
  • SDS
  • Labels

13
Benefits
  • Enhance worker comprehension of hazards,
  • especially for low and limited-literacy workers,
  • reduce confusion in the workplace,
  • facilitate safety training,
  • result in safer handling and use of chemicals
  • Provide workers quicker and more efficient access
    to information on the safety data sheets
    (emergency sections are always 4, 5, 6)
  • Result in cost savings to American businesses in
    productivity improvements, fewer safety data
    sheet and label updates and simpler new hazard
    communication training and
  • Reduce trade barriers by harmonizing with systems
    around the world.

14
Whats the Impact?
  • Rule will impact over 5 million workplaces, and
    43 million workers
  • 650,000 Chemicals used in the USA
  • Annualized savings for employers of between 585
    mil and 798 mil
  • Most of this through increased productivity for
    HS managers and logistics personnel
  • Expect 500 workplace injuries and 43 fatalities
    to be prevented annually as a result of change
  • Savings attributed to uniform SDSs and labels
    accounts for between 16 mil and 32.2 mil

15
Penalties for non-compliance are very real
  • In 2009 2010 combined, OSHA cited over 13,000
    instances of HCS violations in workplaces across
    the United States
  • 3 on OSHA's top 10 list of most frequently
    violated compliance standards

16
Major changes to the Hazard Communication
Standard
  • Hazard classification Provides specific criteria
    for classification of health and physical
    hazards, as well as classification of mixtures.
  • Labels Chemical manufacturers and importers will
    be required to provide a label that includes a
    harmonized signal word, pictogram, and hazard
    statement for each hazard class and category.
    Precautionary statements must also be provided.
  • Safety Data Sheets Will now have a specified
    16-section format.
  • Information and training Employers are required
    to train workers by December 1, 2013 on the new
    labels elements and safety data sheets format to
    facilitate recognition and understanding.

17
Principles Assumptions
  • OSHA has modified only the provisions of the HCS
    that must be changed to align with the GHS
  • The basic framework of the HCS remains the same
  • Chemical manufacturers and importers are
    responsible for providing information about the
    identities and hazards of chemicals they produce
    or import
  • All employers with hazardous chemicals in their
    workplaces are still required to have a hazard
    communication program, and provide information to
    employees about their hazards and associated
    protective measures
  • OSHA has maintained or enhanced the overall
    current level of protection of the HCS

18
Principles Assumptions, cont.
  • Other aspects of the standard have minimal
    modifications in terminology to make them
    consistent with GHS.
  • The scope and application is basically unchanged,
    maintaining practical accommodations made by OSHA
  • Written hazard communication program
    requirements, worker training, and trade secret
    provisions are all largely unchanged from the
    existing rule

19
Other Aspects of the Approach
  • Maintain consistency with major trading partners
    where possible
  • Revise other OSHA standards that will be affected
    by the changes to the HCS
  • Minimize country-specific deviations to be as
    harmonized as possible with GHS provisions

20
Organization of the Final Rule
  • Keep the regulatory text as simple as possible,
    adding the detailed specification requirements to
    Appendices
  • Employers who do not have to classify hazards or
    prepare labels and safety data sheets (SDSs) do
    not need to access or be familiar with much of
    the new text

21
Organization of the Final Rule
  • (a) Purpose
  • (b) Scope and Application
  • (c) Definitions
  • (d) Hazard Classification
  • (e) Written Hazard Communication Program
  • (f) Labels and Other Forms of Warning
  • (g) Safety Data Sheets
  • (h) Employee Information and Training
  • (i) Trade Secrets
  • (j) Effective Dates
  • Appendices A -F

22
Appendices
  • Appendix A, Health Hazard Criteria (Mandatory)
    (NEW)
  • Appendix B, Physical Hazard Criteria (Mandatory)
    (NEW)
  • Appendix C, Allocation of Label Elements
    (Mandatory) (NEW)
  • Appendix D, Safety Data Sheets (Mandatory) (NEW)
  • Appendix E, Definition of Trade Secret
    (Mandatory)
  • Appendix F, Guidance For Carcinogenicity(Non-Manda
    tory) (NEW)

23
Side-by-Side Comparison Of Changes HazComm 1994
versus HazComm 2012
24
a) Purpose
  • HazCom 1994
  • HazCom 2012
  • All hazards to be classified
  • Other provisions the same, except OSHA added that
    the rule is consistent with Revision 3 of the GHS
    (2009 Version)
  • Slight clarifying modification was made to the
    language regarding preemption
  • Federalism
  • All hazards to be evaluated
  • Comprehensive hazard communication program to
    transmit information
  • Preempt state laws

25
Federalism
  • 1910.1200(a)(2) This occupational safety and
    health standard is intended to address
    comprehensively the issue of classifying the
    potential hazards of chemicals, and communicating
    information concerning hazards and appropriate
    protective measures to employees, and to preempt
    any legislative or regulatory enactments of a
    state, or political subdivision of a state,
    pertaining to this subject. Under section 18 of
    the Act, no state or political subdivision of a
    state may adopt or enforce any requirement
    relating to the issue addressed by this Federal
    standard, except pursuant to a Federally-approved
    state plan.

26
b) Scope and Application
  • HazCom 2012
  • HazCom 1994
  • All chemicals known to be present are covered
  • Practical accommodations for special situations
  • Addresses interface with other Federal laws
  • Minimal changes except to conform terminology,
    and remove reference to current Appendix E which
    has been deleted from the standard.

27
c) Definitions
  • HazCom 1994
  • HazCom 2012
  • Physical hazard definitions removed from
    paragraph (c), and placed in a new Appendix B on
    physical hazard classification criteria
  • Following terms are also deleted flashpoint
    (methods included in Appendix B), hazard warning,
    material safety data sheets
  • Some definitions are revised to be
    GHS-consistent,
  • New definitions added for classification
  • Includes specific definitions for terms used in
    the standard, as well as all physical hazards

28
Definitions
  • Terms no longer being defined due to changes in
    terminology
  • Hazard warning identity and material safety
    data sheet (MSDS)
  • Terms revised to be consistent with the GHS
  • Chemical chemical name hazardous chemical
    health hazard label mixture physical hazard
    and trade secret

29
Definitions
  • The following terms are being added to the
    definitions section
  • Classification hazard category hazard class
    hazard not otherwise classified hazard
    statement label elements pictogram
    precautionary statement product identifier
    pyrophoric gas safety data sheet (SDS) signal
    word simple asphyxiant and substance
  • These terms are primarily related to the changes
    in approach to evaluating hazards, and providing
    label /SDS information

30
GHS New Terms
  • Classification identification and evaluation of
    relevant data regarding chemical hazards and
    comparison to GHS criteria
  • Hazard class the nature of the physical or
    health hazard
  • Hazard category division of criteria within
    each hazard class
  • Hazard statement statement assigned to a hazard
    class and category that describes the nature and
    degree of hazard
  • Pictogram symbol plus other graphic elements
    intended to convey specific information about the
    hazards
  • Precautionary statement phrase that describes
    measures that should be taken to minimize or
    prevent adverse effects
  • Safety data sheet (SDS) Material Safety Data
    Sheet (MSDS)
  • Signal word indicates the relative level of
    severity of hazard. Danger is more severe.
    Warning is less severe.

31
Definition of hazardous chemical
  • Any chemical which is classified as a physical
    hazard or a health hazard, a simple asphyxiant,
    combustible dust, pyrophoric gas, or hazard not
    otherwise classified.
  • OSHA used the building block GHS concept to
    include
  • a simple asphyxiant,
  • combustible dust,
  • pyrophoric gas, or
  • hazard not otherwise classified.

ADDED BY OSHA
32
Definitions
  • Hazards Not Otherwise Classified
  • Classification identifies a hazard, but the
    evidence does not meet the currently specified
    criteria covered by HazComm 2012
  • Example Static Accumulator, Magnetic,
    etc.. Example Toxic at less than 1
    concentration

33
d) Hazard Classification
  • HazCom 2012
  • HazCom 1994
  • Performance-oriented
  • Definitions in paragraph (c), Appendices A and B
  • Appendix Bparameters for evaluating data
  • Floor of chemicals considered hazardous
  • One study rule
  • Standardized mixture cut-off rules
  • Specific and detailed
  • Concept of classification vs. determination in
    current rule
  • Each hazard class has detailed criteria to apply
    to data on the chemical
  • No floor based on weight of evidence
  • Mixture rules are specific to each hazard class

34
Hazard Classification
  • Each physical or health hazard is a hazard
    class (e.g., Carcinogenicity is a hazard class)
  • A hazard class may be sub-divided in the
    criteria into several hazard categories based
    on the degree of severity of the hazard
  • Placing a chemical into a hazard class , and
    where necessary, a hazard category, is the
    concept of classification determining not only
    the hazard, but also the severity of the effect

35
Hazard Classification
Hazard Classification
Hazard Type
Hazard Class
Hazard Severity
Hazard Category
36
GHS Hazard Classes
  • Physical
  • Explosives
  • Flammable gases
  • Aerosols
  • Oxidizing gases
  • Gases under pressure
  • Flammable liquids
  • Flammable solids
  • Self-reactive substances and mixtures
  • Pyrophoric liquids
  • Pyrophoric solids
  • Self-heating substances and mixtures
  • Substances and mixtures which in contact with
    water emit flammable gases
  • Oxidizing liquids
  • Oxidizing solids
  • Organic peroxides
  • Corrosive to metals
  • Health
  • Acute toxicity
  • Skin corrosion/irritation
  • Serious eye damage/irritation
  • Respiratory or skin sensitization
  • Germ cell mutagenicity
  • Carcinogenicity
  • Reproductive toxicity
  • Specific target organ toxicity (STOT SE) single
    exposure
  • Specific target organ toxicity (STOT RE)
    repeated exposure
  • Aspiration hazard
  • Environmental
  • Hazardous to the aquatic environment
  • Hazardous to the ozone layer

37
HazComm2012 GHS Hazard Classes
  • Physical
  • Explosives
  • Flammable gases
  • Aerosols
  • Oxidizing gases
  • Gases under pressure
  • Flammable liquids
  • Flammable solids
  • Self-reactive substances and mixtures
  • Pyrophoric liquids
  • Pyrophoric solids
  • Self-heating substances and mixtures
  • Substances and mixtures which in contact with
    water emit flammable gases
  • Oxidizing liquids
  • Oxidizing solids
  • Organic peroxides
  • Corrosive to metals
  • Pyrophoric Gases
  • Combustible Dust
  • Health
  • Acute toxicity
  • Skin corrosion/irritation
  • Serious eye damage/irritation
  • Respiratory or skin sensitization
  • Germ cell mutagenicity
  • Carcinogenicity
  • Reproductive toxicity
  • Specific target organ toxicity (STOT SE) single
    exposure
  • Specific target organ toxicity (STOT RE)
    repeated exposure
  • Aspiration hazard
  • Simple Asphyxiant
  • Environmental
  • Hazardous to the aquatic environment
  • Hazardous to the ozone layer
  • Hazards Not Elsewhere Classified

38
Hazard Classification
  • Manufacturers are still responsible for
    determining the hazards of the chemicals they
    produce or import
  • Classification (similar to hazard determination)
    is based on the full range of available
    information.
  • The procedures for determining if the
    manufacturer has properly performed the hazard
    classification are provided in Appendix A
    (health) and Appendix B (physical)
  • Single Study must be used for classification of
    Carcinogens

39
Health Hazards(Appendix A)
Removed Category 5
Hazard Class Hazard Category Hazard Category Hazard Category Hazard Category
Acute Toxicity 1 2 3 4
Skin Corrosion/Irritation 1A 1B 1C 2
Serious Eye Damage/ Eye Irritation 1 2A 2B
Respiratory or Skin Sensitization 1
Germ Cell Mutagenicity 1A 1B 2
Carcinogenicity 1A 1B 2
Reproductive Toxicity 1A 1B 2 Lactation
STOT Single Exposure 1 2 3
STOT Repeated Exposure 1 2
Aspiration 1
Simple Asphyxiants Single Category Single Category
OSHA Addition
39
40
Hazard Categories
  • Each hazard class has one or more categories of
    hazard, based on severity,
  • eg.Acute Toxicity Oral

LD50 (mg/kg body weight) 5 5 lt LD50 50 50 lt LD50 300 300 lt LD50 2000 2000 lt LD50 5000
GHS Hazard Category Category 1 Category 2 Category 3 Category 4 Category 5
Appendix A used to determine Category for health
hazards
41
Acute Toxicity Oral
LD50 (mg/kg body weight) 5 5 lt LD50 50 50 lt LD50 300 300 lt LD50 2000 2000 lt LD50 5000
GHS Hazard Category Category 1 Category 2 Category 3 Category 4 Category 5
GHSLabel Danger Fatal if swallowed Danger Fatal if swallowed Danger Toxic if swallowed Warning Harmful if swallowed No symbol Warning May be harmful if swallowed
42
(No Transcript)
43
Current HCS vs. HazCom 2012
HCS Corrosive definition
GHS definition/criteria of skin Corrosive
A.2.1.1 Skin corrosion is the production of
irreversible damage to the skin namely, visible
necrosis through the epidermis and into the
dermis, following the application of a test
substance for up to 4 hours. .Corrosive reactions
are typified by ulcers, bleeding, bloody scabs,
and, by the end of observation at 14 days, by
discoloration due to blanching of the skin,
complete areas of alopecia, and scars.
Histopathology should be considered to evaluate
questionable lesions.
  • "Corrosive" A chemical that causes visible
    destruction of, or irreversible alterations in,
    living tissue by chemical action at the site of
    contact. For example, a chemical is considered to
    be corrosive if, when tested on the intact skin
    of albino rabbits by the method described by the
    U.S. Department of Transportation in appendix A
    to 49 CFR part 173, it destroys or changes
    irreversibly the structure of the tissue at the
    site of contact following an exposure period of
    four hours. This term shall not refer to action
    on inanimate surfaces.

Category 1 Corrosive Corrosive sub-categories Corrosive in ? 1 of 3 animals Corrosive in ? 1 of 3 animals
Exposure Observation
1A ? 3 min ? 1 h
1B gt 3 min ? 1 h ? 14 days
1C gt 1 h ? 4 h ? 14 days
44
Health Hazards, cont.
  • For carcinogens - OSHA is allowing classifiers
    to use determinations of IARC/NTP for
    classification instead of performing their own
    hazard evaluation
  • New Appendix F
  • Single Study positive findings must be reported
  • -Where the weight of evidence for the
    carcinogenicity of a substance does not meet the
    above criteria, any positive study conducted in
    accordance with established scientific
    principles, and which reports statistically
    significant findings regarding the carcinogenic
    potential of the substance, must be noted on the
    safety data sheet.

45
Physical Hazards(Appendix B)
ADDED BY OSHA
ADDED BY OSHA
46
(No Transcript)
47
Significant OSHA Decisions
  • The addition of Pyrophoric gas, Simple
    Asphyxiants and Combustible dust to the Physical
    and Health hazards is very significant as these
    are not hazards as defined by GHS

48
Hazards not Otherwise Classified
  • One unique aspect to the OSHAs final rule is the
    definition of hazards not otherwise classified
    (HNOC)
  • This definition was added to ensure that hazards
    currently covered by HCS continue to be covered
  • Combustible Dust has its own hazard class
  • Nanomaterials?
  • Emerging Hazards.

49
Hazards not Otherwise Classified
  • Hazard not otherwise classified (HNOC) means
    an adverse physical or health effect identified
    through evaluation of scientific evidence during
    the classification process that does not meet the
    specified criteria for the physical and health
    hazard classes addressed in this section.
  • This does extend coverage to adverse physical
    and health effects for which there is a hazard
    class addressed in this section, but the effect
    either falls below the cut-off value/concentration
    limit of the hazard class or is under a GHS
    hazard category that has been adopted by OSHA
    (e.g., acute toxicity Category 5, simple
    asphyxiant).

50
Hazards not Otherwise Classified
  • Information will be required on the safety data
    sheets in Section 2
  • Hazard information on the label, is not
    mandatory, but can be provided under
    supplementary information
  • Such hazards must also be addressed in worker
    training

51
Simple Asphyxiant and Pyrophoric Gas
  • Simple asphyxiant means a substance or mixture
    that displaces oxygen in the ambient atmosphere,
    and can thus cause oxygen deprivation in those
    who are exposed, leading to unconsciousness and
    death.
  • Label Warning. May displace oxygen and cause
    rapid suffocation.
  • Pyrophoric gas means a chemical in a gaseous
    state that will ignite spontaneously in air at a
    temperature of 130 degrees F (54.4 degrees C) or
    below.
  • Label Danger. Catches fire spontaneously if
    exposed to air.

52
Combustible Dust
  • Combustible dust is covered separately from HNOC,
    but is not specifically defined
  • Guidance for defining combustible dust is to be
    taken from existing documents, including the
    directive for the National Emphasis Program the
    NFPA standards also provide useful information
  • Combustible dust must be addressed on labels
    where appropriate
  • Warning. May form combustible dust
    concentrations in air.
  • Paragraph (f)(4) may apply to materials shipped
    in solid form, that create combustible dust when
    processed

53
Mixtures
  • HCS 2012 has a tiered approach to mixtures, with
    each health hazard class having a specific
    approach
  • Step 1 Use available test data on the mixture
    as a whole to classify the mixture based on the
    substance criteria
  • Step 2 Use bridging principles to extrapolate
    from other data (e.g., dilution principle)
  • Step 3 Estimate hazards based on known
    information regarding the ingredients of the
    mixture (cut-offs may be applied)
  • Chemical manufacturers and importers may rely on
    the information provided in ingredient SDSs
    unless they have a reason to know that it is
    inaccurate

54
Cut off values/Concentration limits for health
and environmental hazard class
55
Tiered Approach to Classification
  • Generally use test data for the mixture, when
    available
  • ?
  • Use bridging principles, if applicable
  • ?
  • For health and environmental hazards, estimate
    hazards based on the known ingredient information

56
f) Labels and Other Forms of Warning
  • HazCom 1994
  • HazCom 2012
  • Shipped containers to be labeled with product
    identifier signal word hazard statement(s)
    pictograms precautionary statements and
    responsible party
  • Specifies information by hazard class and
    category
  • Shipped containers to be labeled with identity,
    appropriate hazard warnings, and responsible
    party
  • Performance-oriented, specifics left to
    discretion of chemical manufacturer or importer

57
Approach to Labels
  • The final rulelike the GHSis a specification
    approach to labels.
  • In Appendix C, OSHA has indicated by hazard class
    and hazard category the label elements that must
    be on the label
  • Appendix C is basically a cookbook approach to
    labeling
  • Once classification of the hazards is completed,
    Appendix C is to be consulted to determine how to
    convey the required information

58
Label Requirements for Shipped Containers
  1. Product identifier
  2. Signal word
  3. Hazard statement(s)
  4. Pictogram(s)
  5. Precautionary statement(s)
  6. Name, address, and phone number of the
    responsible party

59

60
Precedence of hazard
gt
gt
Skin/Eye irritation
Skin/Eye irritation
gt
gt
DANGER
WARNING
61
Red vs. Black Borders
  • The GHS allows competent authorities to use only
    black borders on pictograms for domestic
    shipments
  • OSHA is requiring red borders regardless of the
    shipments destination
  • The red borders increase comprehensibility
  • The requirement for red borders will result in
    additional options being developed to comply for
    example, new printers are becoming available for
    this requirement
  • Blank red diamonds are not permitted on a label

62
Signal Word Hazard Statements
63
Signal Word
  • Danger or Warning
  • Danger is more hazardous
  • Used to emphasis hazard and to discriminate
    between hazard categories (level of hazard)
  • e.g. Acute toxicity category 1 will require
    Danger, category 4 will require Warning

64
Hazard Statements
  • Dictated by Appendix C

C.4 REQUIREMENTS FOR SIGNAL WORDS, HAZARD STATEMENTS, PICTOGRAMS, AND PRECAUTIONARY STATEMENTS C.4.1 ACUTE TOXICITY ORAL(Classified in Accordance with Appendix A.1) C.4 REQUIREMENTS FOR SIGNAL WORDS, HAZARD STATEMENTS, PICTOGRAMS, AND PRECAUTIONARY STATEMENTS C.4.1 ACUTE TOXICITY ORAL(Classified in Accordance with Appendix A.1) C.4 REQUIREMENTS FOR SIGNAL WORDS, HAZARD STATEMENTS, PICTOGRAMS, AND PRECAUTIONARY STATEMENTS C.4.1 ACUTE TOXICITY ORAL(Classified in Accordance with Appendix A.1) C.4 REQUIREMENTS FOR SIGNAL WORDS, HAZARD STATEMENTS, PICTOGRAMS, AND PRECAUTIONARY STATEMENTS C.4.1 ACUTE TOXICITY ORAL(Classified in Accordance with Appendix A.1)
PictogramSkull and crossbones
Hazard category Signal word Hazard statement
1 Danger Fatal if swallowed
2 Danger Fatal if swallowed
65
Hazard Statements
  • A single harmonised hazard statement for each
    hazard category within each hazard class

e.g. Flammable liquid - Category 1
Extremely flammable liquid and vapour
- Category 2 Highly flammable
liquid and vapour - Category 3
Flammable liquid and vapour -
Category 4 Combustible liquid
66
Hazard Statements (cont.)
  • e.g. Oral Acute Toxicity
  • Category 1
  • Fatal if swallowed
  • Category 2
  • Fatal if swallowed
  • Category 3
  • Toxic if swallowed
  • Category 4
  • Harmful if swallowed
  • Category 5
  • Maybe harmful if swallowed

67
Precautionary Information
  • GHS label should include appropriate
    precautionary information.
  • The GHS document includes examples of
    precautionary statements which can be used.
  • The intent is to harmonize precautionary
    statements.
  • There are four types of precautionary statements
    presented,
  • "prevention,"
  • "response,"
  • "storage," and
  • "disposal."

68
Precautionary InformationExample
Precautionary statements Precautionary statements Precautionary statements Precautionary statements
Prevention Response Storage Disposal
Wash thoroughly after handling. Chemical manufacturer, importer, or distributor to specify parts of the body to be washed after handling. Do not eat, drink or smoke when using this product. If swallowed Immediately call a poison center/doctor/ Chemical manufacturer, importer,or distributor to specify the appropriate source of emergency medical advice. Specific treatment (see on this label) Reference to supplemental first aid instruction. - if immediate administration of antidote is required. Rinse mouth. Store locked up. Dispose of contents/container to ... in accordance with local/regional/national/international regulations (to be specified).
69
Examples of Precautionary Pictograms (Not
Mandatory)
70
Label Example
HazCom 2012 Minimum Requirements
HazCom 1994 Minimum requirements

71
New Label Requirements
GHS Label
Workplace Label
XYZ Chemical, 234 E. 3rd St Murray KY 42071
227.777.6565
  • Updated OSHA GHS Standard
  • Product identifier
  • Signal word
  • Hazard statements
  • Precautionary statements
  • Pictograms
  • Supplier information
  • Supplemental information

XYZ Chemical, 234 E. 3rd St Murray KY 42071
227.777.6565
  • Current OSHA Standard
  • Material identity
  • Hazard warnings
  • Supplier information

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GHS Label-Bad Example-Toxic?
76
Updating Labels
  • OSHA proposed to require labels to be updated
    within three months of getting new and
    significant information about the hazards
  • The final rule requires containers shipped six
    months after the information is available to be
    labeled accordingly

77
Workplace Labels
  • HazCom 2012 maintains the flexible approach to
    workplace labels in the current rule, i.e., the
    GHS label does not have to be on all workplace
    containers
  • May Still use other label systems in Plant
  • NFPA labels (problem with reverse hazard
    numbering)
  • HMIS labels
  • Workplace labels will have to be reviewed to make
    sure they still convey the correct hazards and
    other information when these new requirements are
    implemented

78
The NFPA 704 System
79
Labels
  • Employers are responsible for maintaining the
    labels on the containers, including, but not
    limited to, tanks, totes, drums, and for training
    their employees on the hazards listed on the
    labels in the workplace.
  • Labels must continue to be
  • legible
  • contain the pertinent information (such as the
    hazards and directions for use)
  • not able to be defaced, (i.e., fade, get washed
    off,) or removed in any way as stated in revised
    Hazard Communication Standard, 29
    CFR 1910.1200(f)(9)

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g) Safety Data Sheets
  • HazCom 1994
  • HazCom 2012
  • Mandates 16-section SDS headings, order of
    information, and what information is to be
    provided under the headings
  • Will not enforce sections 12-15 that require
    information outside OSHAs jurisdiction
  • Specifies what information is required, but
    chemical manufacturer or importer can use
    whatever format or order of information they want

81
16 section - Safety Data Sheet
  • 1.Identification of the substance or mixture and
    of the supplier
  • 2.Hazards identification
  • 3.Composition/information on ingredients
    Substance/Mixture
  • 4.First aid measures
  • 5.Firefighting measures
  • 6.Accidental release measures
  • 7.Handling and storage
  • 8.Exposure controls/personal protection.
  • 9.Physical and chemical properties
  • 10.Stability and reactivity
  • 11.Toxicological
  • 12.Ecological information (non mandatory)
  • 13.Disposal considerations (non mandatory)
  • 14.Transport information (non mandatory)
  • 15.Regulatory information (non mandatory)
  • 16.Other information including information on
    preparation and revision of the SDS 

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1910.1200(g)(2) And Appendix D
  • Specifies the minimum information to be included
    in each of the 16 sections.
  • Two revisions in this information are in the
    final rule
  • ACGIH TLVs continue to be required on the SDS
  • Information regarding carcinogenicity
    classifications by IARC and NTP also continue to
    be required
  • Appendix C presents standardized hazard Signal
    word, Hazard statement(s),Pictogram(s), and
    Precautionary statement(s) to be included in
    section 2 of the SDS

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Safety Data Sheets Key Changes
Safety Data Sheets Key Changes
Section 2 Hazard(s) Identification
  • GHS Classification
  • Pictogram(s)
  • Signal Word
  • Hazard Statement
  • PrecautionaryStatement

84
SDS Sections
  • From Appendix D

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SDS Section 1
  • Identification
  • (a) Product identifier used on the label(b)
    Other means of identification(c) Recommended
    use of the chemical and restrictions on use(d)
    Name, address, and telephone number of the
    chemical manufacturer, importer, or other
    responsible party(e) Emergency phone number.

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SDS Section 2
  • Hazard(s) identification
  • a) Classification of the chemical in accordance
    with paragraph (d) of 1910.1200(b) Signal
    word, hazard statement(s), symbol(s) and
    precautionary statement(s) in accordance with
    paragraph (f) of 1910.1200. (Hazard symbols may
    be provided as graphical reproductions in black
    and white or the name of the symbol, e.g., flame,
    skull and crossbones)(c) Describe any hazards
    not otherwise classified that have been
    identified during the classification process(d)
    Where an ingredient with unknown acute toxicity
    is used in a mixture at a concentration 1 and
    the mixture is not classified based on testing of
    the mixture as a whole, a statement that X of
    the mixture consists of ingredient(s) of unknown
    acute toxicity is required

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SDS Section 3
Composition/ information on ingredients
  • For Substances
  • (a) Chemical name(b) Common name and
    synonyms(c) CAS number and other unique
    identifiers(d) Impurities and stabilizing
    additives which are themselves classified and
    which contribute to the classification of the
    substance.

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SDS Section 3
Composition/ information on ingredients
  • For MixturesIn addition to the information
    required for substances
  • (a) The chemical name and concentration (exact
    percentage) or concentration ranges of all
    ingredients which are classified as health
    hazards in accordance with paragraph (d) of
    1910.1200 and(1) are present above their
    cut-off/concentration limits or (2) present a
    health risk below the cut-off/concentration
    limits. (b) The concentration (exact percentage)
    shall be specified unless a trade secret claim is
    made in accordance with paragraph (i) of
    1910.1200, when there is batch-to-batch
    variability in the production of a mixture, or
    for a group of substantially similar mixtures
    (See A.0.5.1.2) with similar chemical
    composition. In these cases, concentration ranges
    may be used.

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SDS Section 3
Composition/ information on ingredients
  • For All Chemicals Where a Trade Secret is Claimed
  • Where a trade secret is claimed in accordance
    with paragraph (i) of 1910.1200, a statement
    that the specific chemical identity and/or exact
    percentage (concentration) of composition has
    been withheld as a trade secret is required.

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SDS Section 4
  • First-aid measures
  • (a) Description of necessary measures, subdivided
    according to the different routes of exposure,
    i.e., inhalation, skin and eye contact, and
    ingestion(b) Most important symptoms/effects,
    acute and delayed.(c) Indication of immediate
    medical attention and special treatment needed,
    if necessary.

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SDS Section 5
  • Fire-fighting measures
  • (a) Suitable (and unsuitable) extinguishing
    media.(b) Specific hazards arising from the
    chemical (e.g., nature of any hazardous
    combustion products).(c) Special protective
    equipment and precautions for fire-fighters.

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SDS Section 6
  • Accidental release measures
  • (a) Personal precautions, protective equipment,
    and emergency procedures.(b) Methods and
    materials for containment and cleaning up.

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SDS Section 7
  • Handling and storage
  • (a) Precautions for safe handling.(b) Conditions
    for safe storage, including any incompatibilities.

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SDS Section 8
  • Exposure controls/personal protection
  • (a) OSHA permissible exposure limit (PEL),
    American Conference of Governmental Industrial
    Hygienists (ACGIH) Threshold Limit Value (TLV),
    and any other exposure limit used or recommended
    by the chemical manufacturer, importer, or
    employer preparing the safety data sheet, where
    available.(b) Appropriate engineering
    controls.(c) Individual protection measures,
    such as personal protective equipment.

95
SDS Section 9
  • Physical and chemical properties
  • (a) Appearance (physical state, color, etc.)(b)
    Odor(c) Odor threshold(d) pH(e) Melting
    point/freezing point(f) Initial boiling point
    and boiling range(g) Flash point(h)
    Evaporation rate(i) Flammability (solid,
    gas)(j) Upper/lower flammability or explosive
    limits(k) Vapor pressure(l) Vapor
    density(m) Relative density(n)
    Solubility(ies)(o) Partition coefficient
    n-octanol/water(p) Auto-ignition
    temperature(q) Decomposition temperature(r)
    Viscosity.

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SDS Section 10
  • Stability and reactivity
  • (a) Reactivity(b) Chemical stability(c)
    Possibility of hazardous reactions(d)
    Conditions to avoid (e.g., static discharge,
    shock, or vibration)(e) Incompatible
    materials(f) Hazardous decomposition products.

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SDS Section 11
  • Toxicological information
  • (a) Information on the likely routes of exposure
    (inhalation, ingestion, skin and eye
    contact)(b) Symptoms related to the physical,
    chemical and toxicological characteristics(c)
    Delayed and immediate effects and also chronic
    effects from short- and long-term exposure(d)
    Numerical measures of toxicity (such as acute
    toxicity estimates).(e) Whether the hazardous
    chemical is listed in the National Toxicology
    Program (NTP) Report on Carcinogens (latest
    edition) or has been found to be a potential
    carcinogen in the International Agency for
    Research on Cancer (IARC) Monographs (latest
    edition), or by OSHA.

98
SDS Section 12
  • Ecological information (Non-mandatory)
  • (a) Ecotoxicity (aquatic and terrestrial, where
    available)(b) Persistence and
    degradability(c) Bioaccumulative potential(d)
    Mobility in soil(e) Other adverse effects (such
    as hazardous to the ozone layer).

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SDS Section 13
  • Disposal considerations (Non-mandatory)
    Description of waste residues and information on
    their safe handling and methods of disposal,
    including the disposal of any contaminated
    packaging.

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SDS Section 14
  • Transport information (Non-mandatory)
  • (a) UN number(b) UN proper shipping name(c)
    Transport hazard class(es)(d) Packing group, if
    applicable(e) Environmental hazards (e.g.,
    Marine pollutant (Yes/No))(f) Transport in bulk
    (according to Annex II of MARPOL 73/78 and the
    IBC Code)(g) Special precautions which a user
    needs to be aware of, or needs to comply with, in
    connection with transport or conveyance either
    within or outside their premises.

101
SDS Section 15
  • Regulatory information (Non-mandatory) Safety,
    health and environmental regulations specific for
    the product in question.
  • State/local laws
  • OSHA expanded Health Standards

102
SDS Section 16
  • Other information, including date of preparation
    or last revision
  • The date of preparation of the SDS or the last
    change to it.

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Safety Data Sheets (SDS)
  • SDS in the workplace for each hazardous chemical
    which is used
  • Readily accessible during each work shift to
    employees when they are in their work area(s)

104
h) Employee Information and Training
  • HazCom 1994
  • HazCom 2012
  • Clarifies that the labels on shipped containers
    and workplace labels must be explained, as well
    as SDS format
  • Workers will have to be trained on the new label
    and SDS formats before all the provisions of the
    rule are effective
  • Requires employee information and training before
    a worker is exposed to the hazardous chemicals in
    the workplace, and whenever the hazard changes

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Training
  • Since the new label and SDS requirements will be
    phased in over several years, it is critical that
    employees understand the label and SDS formats,
    and the way information is conveyed
  • Training on the system is thus the first
    compliance date for the rule workers are
    already starting to see GHS labels and SDSs on
    imported chemicals

106
Employee Training
  • Location of program, list of chemical, and SDS
  • Detection of chemical
  • Hazards of chemical
  • Protection measures
  • Emergency procedures
  • Labeling system used
  • Trained initially and when new chemical
    introduced
  • OSHA standard covered
  • Operations in their work area where chemical is
    used
  • Pictograms

107
i) Trade Secrets(AppendixE)
  • HazCom 2012
  • HazCom 1994
  • Process remains the same
  • Percentage of a substance in a mixture is also
    considered to be a type of trade secret subject
    to the provisions in the rule.
  • Allows specific chemical identity to be protected
    when it is a legitimate trade secrete.
  • Specifies conditions for protection, and for
    release when there is a safety and health need
    for the information

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Implementation Dates
Effective Completion Date Requirement(s) Who
December 1, 2013 Train employees on the new label elements and SDS format. Employers
June 1, 2015December 1, 2015 Comply with all modified provisions of this final rule, exceptDistributors may ship products labeled by manufacturers under the old system until December 1, 2015. Chemical manufacturers, importers, distributors and employers
June 1, 2016 Update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards. Employers
Transition Period Comply with either 29 CFR 1910.1200 (this final standard), or the current standard, or both. All chemical manufacturers, importers, distributors and employers
This date coincides with the European Union
implementation date for classification of
mixtures.
109
Approach to Other Standards
  • Many other OSHA standards contain criteria
    related to defining hazards, as well as other
    provisions that rely on those criteria
  • OSHA undertook a comprehensive review of its
    rules to identify what needed to be changed
  • OSHA has proposed modifications to all of those
    standards that it determined needed to be
    consistent with the GHS

110
Written Program
  • Describes how the standard will be implemented in
    that facility  
  • Contains a list of all chemicals

111
Program Requirements
  • Written program
  • List of all hazardous chemicals
  • Addresses non-routine tasks
  • Discusses other contractors responsibilities
  • Available upon request to any employee or
    contractor

112
Develop Implementation Plans
  • For Employers
  • Initial employee training on the label elements
  • Minimal training on new SDS format
  • Continue to maintain the updated SDSs
  • Review current hazard communication program and
    update as necessary
  • For manufacturers
  • Initial start-up costs associated with
    reclassification, producing new labels, safety
    data sheets, training.

113
Guidance Materials
  • OSHA has and will continue to develop an array of
    guidance materials
  • Initial Materials
  • Quick Cards, Fact sheets, Small Entity Compliance
    guides
  • Technical Materials
  • Model Training materials Safety Data Preparation
    guidance Hazard Classification Guidance
  • Web Applications
  • http//www.osha.gov/dsg/hazcom/index.html

114
Impact on RCRA
  • HazCom 2012 continues to exempt hazardous waste
    under 1910.1200(b)(6).
  • Employers will need to train their employees on
    the new label and SDS requirements
  • Use in the workplace
  • Use in emergency response and contingency planning

115
Effect on Safety Professionals
  • Become familiar with the new system
  • Collect new SDSs as provided by suppliers and
    incorporate them into the existing MSDS system
    (or use commercial service)
  • New GHS labels for shipped containers
  • Employers can use other systems for workplace
    labeling
  • Train employees on new labels and SDS

116
For More Information
  • GHS text, UN papers and reports
  • www.unece.org/trans/danger/danger.htm
  • OSHA GHS information
  • http//www.osha.gov/dsg/hazcom/index.html
  • EPA GHS information
  • www.epa.gov/oppfead1/international/globalharmon.h
    tm
  • DOT GHS information
  • www.hazmat.dot.gov/regs/intl/globharm.htm
  • Canada GHS information
  • http//www.hc-sc.gc.ca/ewh-semt/occup-travail/whm
    is-simdut/ghs-sgh/index_e.html

117
Reference Material
  • Detailed Side-By-Side Review of the Regulatory
    Text Changes
  • See OSHA Web Page at
  • http//www.osha.gov/dsg/hazcom/side-by-side.html
  • Federal Register (includes Preamble for
    reference)
  • http//www.osha.gov/pls/oshaweb/owadisp.show_docum
    ent?p_tableFEDERAL_REGISTERp_id22607
  • QA on the New Standard
  • http//www.osha.gov/dsg/hazcom/hazcom-faq.html

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Questions?
120
Employee Training Program Framework Example
  • Must be made site-specific and
  • Health hazard slides added/modified to include
    specific examples of chemicals used by the
    individual employer.
  • Labels
  • SDSs
  • The specific employers policies, procedures and
    responsible employees need to be identified and
    discussed (overall facilitys program details)

121
The GHS (HazComm 2012) Elements
  • Classification Criteria
  • Health
  • Environment
  • Physical
  • Hazards not Elsewhere Classified
  • Hazard Communication
  • Labels
  • Safety Data Sheets

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Hazard Classification
  • Chemical substances and mixtures are classified
    according to 18 physical and 11 health hazard
    classes
  • Most hazard classes are sub-divided into hazard
    categories based on severity where, for example,
    1 is high and 5 is low.
  • GHS allows for use of expert judgment and weight
    of evidence.
  • Classification determines the signal words,
    pictograms, hazard and precautionary statements
    used to convey information on labels and safety
    data sheets (SDS).
  • Adoption of GHS by OSHA does not affect DOT
    regulations as the classification and labeling of
    hazardous materials in transport have been
    harmonized for years.

123
HazComm2012 GHS Hazard Classes
  • Physical
  • Explosives
  • Flammable gases
  • Aerosols
  • Oxidizing gases
  • Gases under pressure
  • Flammable liquids
  • Flammable solids
  • Self-reactive substances and mixtures
  • Pyrophoric liquids
  • Pyrophoric solids
  • Self-heating substances and mixtures
  • Substances and mixtures which in contact with
    water emit flammable gases
  • Oxidizing liquids
  • Oxidizing solids
  • Organic peroxides
  • Corrosive to metals
  • Pyrophoric Gases
  • Combustible Dust
  • Health
  • Acute toxicity
  • Skin corrosion/irritation
  • Serious eye damage/irritation
  • Respiratory or skin sensitization
  • Germ cell mutagenicity
  • Carcinogenicity
  • Reproductive toxicity
  • Specific target organ toxicity (STOT SE) single
    exposure
  • Specific target organ toxicity (STOT RE)
    repeated exposure
  • Aspiration hazard
  • Simple Asphyxiant
  • Environmental
  • Hazardous to the aquatic environment
  • Hazardous to the ozone layer
  • Hazards Not Elsewhere Classified

124
The GHS ClassificationHealth Environmental
Hazards
  • Acute Toxicity
  • Skin Corrosion/Irritation
  • Serious Eye Damage/Eye Irritation
  • Respiratory or Skin Sensitization
  • Germ Cell Mutagenicity
  • Carcinogenicity
  • Reproductive Toxicity
  • Target Organ Systemic Toxicity Single and
    Repeated Dose
  • Simple Asphyxiant
  • Hazardous to the Aquatic Environment

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Health Hazards
Hazard Class Hazard Category Hazard Category Hazard Category Hazard Category
Acute Toxicity 1 2 3 4
Skin Corrosion/Irritation 1A 1B 1C 2
Serious Eye Damage/ Eye Irritation 1 2A 2B
Respiratory or Skin Sensitization 1
Germ Cell Mutagenicity 1A 1B 2
Carcinogenicity 1A 1B 2
Reproductive Toxicity 1A 1B 2 Lactation
STOT Single Exposure 1 2 3
STOT Repeated Exposure 1 2
Aspiration 1
Simple Asphyxiants Single Category Single Category
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126
Physical Hazards
  • Explosives
  • Flammability gases, aerosols, liquids, solids
  • Oxidizers liquid, solid, gases
  • Self-Reactive
  • Pyrophoric liquids, solids
  • Self-Heating
  • Organic Peroxides
  • Corrosive to Metals
  • Gases Under Pressure
  • Water activated flammable gases
  • Definitions, test methods and classification
    criteria are based on existing transport system
    (DOT Regulations)

127
Physical Hazards
128
System of Information and Communication
  • Hazard Class
  • Pictogram
  • Signal Word
  • Danger or Warning
  • Hazard Statement
  • i.e. combustible liquid,
  • Precautionary Statement
  • There are four types of precautionary statements
    presented
  • "prevention,"
  • "response,"
  • "storage," and
  • "disposal."

129
GHS Pictogram for Hazard Class
Explosives Self-reactive subst. Organic peroxide

Flammable substance Self-reactive substance
Pyrophoric and self- heating substance
Oxidizing substance Organic peroxides
Compressed gas
Sensitization (Respiratory) Mutagenicity
Carcinogenicity Reproductive toxicity Target
organ toxicity
Skin corr. Eye corr. Corrosive to metal
Acute toxicity
Acute toxicity Skin irrit. Eye irrit.
Sensitization (Dermal)
Environmental toxicity
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Precedence of hazard
gt
gt
Skin/Eye irritation
Skin/Eye irritation
gt
gt
DANGER
WARNING
131
Transport Pictograms
Included in addition to GHS Pictograms and must
be maintained
132
Signal Word
  • Danger or Warning
  • Danger is more hazardous
  • Used to emphasis hazard and to discriminate
    between hazard categories (level of hazard)
  • e.g. Acute toxicity category 1 will require
    Danger, category 4 will require Warning

133
Hazard Category within a Hazard Class
  • Hazard Categories are further subdivided into
    Hazard Classes
  • Health Hazards
  • Physical Hazards
  • 1 is more hazardous than 4
  • Opposite of NFPA Label System

134
The NFPA 704 System
135
Hazard Statements
  • A single harmonised hazard statement for each
    hazard category within each hazard class

e.g. Flammable liquid - Category 1
Extremely flammable liquid and vapour
- Category 2 Highly flammable
liquid and vapour - Category 3
Flammable liquid and vapour -
Category 4 Combustible liquid
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Hazard Statements (cont.)
  • e.g. Oral Acute Toxicity
  • Category 1
  • Fatal if swallowed
  • Category 2
  • Fatal if swallowed
  • Category 3
  • Toxic if swallowed
  • Category 4
  • Harmful if swallowed
  • Category 5
  • Maybe harmful if swallowed

137
Allocation of Label Elements
Example Acute Toxicity (Oral)
138
Allocation of Label Elements (cont.)
Example Skin Corrosion/Irritation
139
Building Block Approach (Health)
Example Acute Toxicity (Oral)
Category 1 Category 2 Category 3 Category 4 Category 5
Danger Fatal if swallowed Danger Fatal if swallowed Danger Toxic if swallowed Warning Harmful if Swallowed No Symbol Warning May be harmful if swallowed
Not required under the TDG/MR Not required under the TDG/MR
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Building Block Approach (Physical)
Example Explosives
Unstable/ Division 1.1 Division 1.2 Division 1.3 Division 1.4 Division 1.5 Division 1.6
Danger  Explosive mass explosion hazard   Danger Explosive severe projection hazard Danger  Explosive fire, blast or projection hazard 1.4  Warning  Fire or projection hazard 1.5  Warning  May explode in fire 1.6

141
Precautionary Statements
  • There are four types of precautionary statements
    presented
  • "prevention,"
  • "response,"
  • "storage," and
  • "disposal."

142
  • Epichlohydrin
  • 1-Chloro-2,3-epoxypropane
  • CAS No. 106-89-8
  • UN No. 2023
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