FROM HAZCOM TO GHS Comparing Classification Requirements

Date First Published on SafetySmart Compliance: April 5th, 2012
Topics: GHS Transition | HazCom |

FROM HAZCOM TO GHS Comparing Classification Requirements

ISSUE

CURRENT HAZCOM

GHS

Process used by chemical manufacturers and importers to evaluate hazards of their products

Requires chemical manufacturers and importers to use a process called hazard determination to evaluate health hazards and physical hazards of their products.

Requires manufacturers and importers to use a process called Classification to evaluate hazards of their products.  Companies don’t do actual testing; instead, they evaluate scientific evidence available & identify hazards. Based on data, they classify products by :

Hazard Class, i.e., the nature of the physical or health hazards, e.g., flammable, solid, carcinogen, oral acute toxicity; and, if applicable:

Hazard Category, i.e., division of criteria within each hazard class. Example: Oral acute toxicity and flammable liquids include 4 hazard categories. The categories compare hazard severity within a hazard class and shouldn’t be taken as a comparison of hazard categories more generally.

What makes a chemical hazardous

Chemicals are hazardous—and covered by standard—if they’re:

  • Health hazards; or
  • Physical hazards

Chemicals are hazardous—and covered by standard—if they’re:

  • Health hazards (see below);
  • Physical hazards (see below);
  • Simple asphyxiants, i.e., substances or mixtures that displace oxygen in ambient atmosphere & cause oxygen deprivation leading to unconsciousness & death
  • Combustible dusts;
  • Pyrophoric gases, i.e., chemicals in gaseous state that ignite spontaneously in air at 130° F (54.4° C) or below; or
  • Hazards not otherwise classified, i.e., an adverse physical or health effect identified through evaluation of scientific evidence during classification process that doesn’t meet criteria for physical and health hazard classes of the standard. This does not extend coverage to adverse physical and health effects for which there’s 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 hasn’t been adopted by OSHA (e.g., acute toxicity Category 5)

What constitutes a “health hazard”

A chemical for which there’s statistically significant evidence based on at least 1 study done according to scientific principles that acute or chronic health effects may occur in exposed employees. Includes carcinogens, toxic or highly toxic agents, reproductive toxins, irritants, corrosives, sensitizers, hepatoxins, nephrotoxins, neurotoxins, agents that act on the hematopoleic system, and agents that damage lungs, skin, eyes or mucuous membranes.

Appendix A of Standard sets out criteria for Health Hazards

A chemical classified as having 1 of following hazardous effects:

* Acute toxicity (any route of exposure);

*  Skin corrosion or irritation;

* Serious eye damage or eye irritation;

* Respiratory or skin sensitization;

* Germ cell mutagenicity;

* Carcinogenicity;

* Specific target organ toxicity (single or repeat exposure); or

* Aspiration hazard.

Appendix A of GHS Rule sets out criteria for Health Hazards

What constitutes a “physical hazard”

A chemical for which there’s scientifically valid evidence that it’s a combustible liquid, compressed gas, explosive, flammable, organic peroxide, oxidizer, pyrophoric, unstable (reactive), or water reactive

A chemical that’s classified as posing 1 of the following hazardous effects:

* Explosive;

* Flammable (gases, aerosols, liquids, or solids);

* Oxidizer (liquid, solid or gas);

* Self-reactive;

* Pyrophoric (liquid or solid);

* Self-heating;

* Organic peroxide;

* Corrosive to metal;

* Gas under pressure; or

* In contact with water emits flammable gas.

Appendix B of GHS Rule lists criteria for Physical Hazards

New criteria for classifying mixtures

Requires manufacturers and importers to determine health and physical hazards of mixtures of their products based on how mixtures are tested, e.g., as a whole or by individual ingredient

Requires manufacturers and importers to determine health and physical hazards of mixtures of their products using procedures set out in new Appendix A and Appendix B. Manufacturers or importers can rely on information in current SDS of individual ingredients unless they “know, or in the exercise of reasonable diligence should know” that SDS misstates or omits information required by standard.

 
 
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