Adopting A Unitary Chemical Labeling System

Multiple systems for MSDS [Material Safety Data Sheet] development and for labeling hazardous chemicals and materials have been adopted in many countries.

Bob Eckhardt

Multiple systems for MSDS [Material Safety Data Sheet] development and for labeling hazardous chemicals and materials have been adopted in many countries. The United States alone has at least four labeling systems and three MSDS standards.

Among U.S. labeling systems is one created by the Department of Transportation for conveying hazardous materials, while the U.S Hazard Communication (HazCom) standard incorporates several options. Predictably, significant confusion results when co-existing systems are used.

The HazCom standard simply requires manufacturers and users to assure that specified hazards are clearly identified on the container. Three primary labeling systems for hazardous substances in the U.S. include the NFPA Hazard Identification System, the Hazardous Material Identification Guide (HMIG), and the Hazardous Material Identification System (HMIS). A new standard proposed by the Occupational Safety and Health Administration would eliminate these three systems.

Earlier this fall, OSHA published an advance notice of proposed rulemaking seeking public comment on the Hazard Communication System (HCS) program for the adoption of the Globally Harmonized System of Classification and Labeling of Chemicals, known as GHS. The system has been adopted by the United Nations in an effort to harmonize labeling practices worldwide. Now available for implementation, GHS is promulgated globally: countries are encouraged to implement GHS with the goal of a fully operational world system by 2008. That goal was adopted by nations in the Intergovernmental Forum on Chemical Safety, as well as endorsed by the World Summit on Sustainable Development. In addition, countries involved in the Asia-Pacific Economic Cooperation have endorsed a goal of 2006. The U.S. participates in these international groups as a party in the effort to achieve their stated aims.

GHS provisions for classification of chemicals target their health, physical, and environmental effects. The all-encompassing standard specifies labeling for transportation, workplace use, manufacturer containers, and pesticides, as well as a new format for (material) safety data sheets.

One obvious shift will be a name change from Material Safety Data Sheet, or MSDS, to Safety Data Sheet, or SDS. Essentially identical are the GHS and the ISO systems for SDS development. Currently, ISO, ANSI, and OSHA criteria are available for the development of safety data sheets. U.S. adoption of the system would effectively eliminate use of the ANSI standard and the already antiquated OSHA MSDS criteria.

Far reaching in the United States, the proposed system could affect numerous standards. Several regulatory authorities now exercise jurisdiction over chemical hazard communication. In addition to OSHA’s HCS, the Department of Transportation regulates chemicals in transport; the Consumer Product Safety Commission (CPSC) oversees consumer products; and, the Environmental Protection Agency (EPA) targets pesticides, exercising labeling authority as well under the Toxic Substances Control Act. These regulatory agencies operate under different statutory mandates and apply varying approaches to hazard communication requirements. Numerous statutes reference or adopt various sections of HCS.

While a few changes would be in order to comply with the proposed standard, DOT labeling requirements for hazardous materials transportation are nearly identical to those of GHS. Since OSHA is not harmonized with current DOT standards, changing HCS to incorporate GHS criteria would ensure consistency of DOT and OSHA requirements.

A major benefit of adopting GHS would be to further align domestic labeling with world practices, thereby reducing the number of labels and labeling systems that U.S. and foreign manufacturers would necessarily maintain for the same product. Today, some countries require a distinct labeling system; for example, Canada adheres to the Workplace Hazardous Materials Information System (WHMIS), which requires that labels include specified symbols within a defined circle. U.S. chemical manufacturers must label chemicals accordingly for Canadian markets. Thus, Canada may also elect to adopt GHS in the near future.

What will the GHS label look like? Transport pictograms will look much like U.S. DOT diamonds for hazardous materials. While label format or layout is not specified in the GHS, the hazardous substances label must include hazard pictograms, signal word, and hazard statements in a common configuration.

Additional information regarding OSHA’s adoption of GHS is available at the agency’s website, www.osha.gov. OSHA also advises the public to contact Maureen O’Donnell, industrial hygienist, or David O’Connor, health scientist, Directorate of Standards and Guidance, Room N3718, U.S. Department of Labor, 200 Constitution Avenue, N.W., Washington, DC 20210; phone: 202/693-1950.

MATERIAL SAFETY DATA SHEET COMPARISON
MSDS SECTIONS	GHS SDS¹	ISO MSDS²	ANSI MSDS³	OSHA MSDS⁴
1. Product and company identification	GHS product identifier Other means of identification Recommended use of the chemical and restrictions on use Supplier’s details (including name, address, phone number) Emergency phone number	GHS product identifier Other means of identification Recommended use of the chemical and restrictions on use Supplier’s details (including name, address, phone number) Emergency phone number	Product identity same as on label Product name, product code Name, address and phone number of supplier Emergency phone number	Product identity same as on label. Name address and phone number of the manufacturer, distributor, employer or other responsible party
2. Hazards identification	GHS classification of the substance/mixture and any regional information GHS label elements, including precautionary statements [Hazard symbols may be provided as a graphical reproduction of the symbols in black and white or the name of the symbol, e.g., flame, skull and crossbones.] Other hazards that do not result in classification (e.g., dust explosion hazard) or are not covered by GHS	GHS classification of the substance/mixture and any regional information GHS label elements, including precautionary statements [Hazard symbols may be provided as a graphical reproduction of the symbols in black and white or the name of the symbol, e.g., flame, skull and crossbones.] Other hazards that do not result in classification (e.g., dust explosion hazard) or are not covered by GHS	Emergency Overview [description of product and most significant immediate physical, health and environmental concerns] OSHA Regulatory Status Potential health effects [information on adverse human health effects and symptoms, relevant route(s) and length of exposure, type and severity of effects, target organs, medical symptoms that are aggravated by exposure] If listed as a carcinogen by OSHA, IARC, NTP Environmental effects	Health hazards, including acute and chronic effects, listing target organs or systems Signs and symptoms of exposure Conditions generally recognized as aggravated by exposure Primary routes of exposure If listed as a carcinogen by OSHA, IARC, NTP Physical hazards, including the potential for fire, explosion, and reactivity
3. Composition/information on ingredients	Substance Chemical identity Common name, synonyms CAS number, EC number, etc. Impurities and stabilizing additives, which are themselves classified and that contribute to the classification of the substance Mixture Chemical identity and concentration or concentration ranges of all ingredients that are hazardous within the meaning of GHS and are present above their cut-off levels. Cut-off level for reproductive toxicity, carcinogenicity and category 1 mutagenicity is³ 0.1% Cut-off level for all other hazard classes is³ 0.1% Note: For information on ingredients, the competent authority rules for CBI take priority over the rules for product identification	Substance Chemical identity Common name, synonyms CAS number, EC number, etc. Impurities and stabilizing additives, which are themselves classified and that contribute to the classification of the substance Mixture Chemical identity and concentration or concentration ranges of all ingredients that are hazardous within the meaning of GHS and are present above their cut-off levels. Cut-off level for reproductive toxicity, carcinogenicity and category 1 mutagenicity is³ 0.1% Cut-off level for all other hazard classes is³ 0.1%	Common chemical name(s) Generic name(s) Synonyms CAS number(s) Components or impurities contributing to the hazard (name, concentration)	Chemical and common name of ingredients contributing to known hazards For untested mixtures, the chemical and common name of ingredients at 1% or more that present a health hazard and those that present a physical hazard in the mixture Ingredients at 0.1% or greater, if carcinogens
4. First-aid measures	Description of necessary measures, subdivided according to different routes of exposure, i.e., inhalation, skin and eye contact and ingestion Most important symptoms/effects, acute and delayed Indication of immediate medical attention and special treatment needed, if necessary	Description of necessary measures, subdivided according to different routes of exposure, i.e., inhalation, skin and eye contact and ingestion Most important symptoms/effects, acute and delayed Indication of immediate medical attention and special treatment needed, if necessary	First aid procedures by route of exposure, i.e., inhalation, skin contact, eye contact, ingestion Important symptoms and effects useful for diagnostic treatment Antidotes Notes to a physician	Emergency and first aid procedures
5. Firefighting measures	Suitable (and unsuitable) extinguishing media Specific hazards arising from the chemical (e.g., nature of any hazardous combustion products) Special protective equipment and precautions for firefighters	Suitable (and unsuitable) extinguishing media Specific hazards arising from the chemical (e.g., nature of any hazardous combustion products) Special protective equipment and precautions for firefighters	Qualitative flammable and reactivity properties Suitable extinguishing media Unsuitable extinguishing media Guidance to firefighters Specific hazards arising from the chemical Protective equipment and precautions for firefighters	Generally applicable control measures Flammable property information such as flashpoint Physical hazards, including the potential for fire, explosion, and reactivity
6. Accidental release measures	Personal precautions, protective equipment and emergency procedures Environmental precautions Methods and materials for containment and cleanup	Personal precautions, protective equipment and emergency procedures Environmental precautions Methods and materials for containment and cleanup	Clean-up technique Personal precautions Environmental precautions Containment technique Regulatory information	Procedures for clean up of spills and leaks
7. Handling and storage	Precautions for safe handling Conditions for safe storage, including any incompatibilities	Precautions for safe handling Conditions for safe storage, including any incompatibilities	Handling Measures to prevent exposure and release, prevent fire or explosion and ensure precautions for safe handling Storage Storage conditions and technical measures for safe storage Incompatibilities Suitable/nonsuitable packaging material	Precautions for safe handling and use, including appropriate hygienic practices
8. Exposure controls/personal protection	Control parameters (e.g., occupational exposure limit values or biological limit values) Appropriate engineering controls Individual protection measures, such as personal protective equipment	Control parameters (e.g., occupational exposure limit values or biological limit values) Appropriate engineering controls Individual protection measures, such as personal protective equipment	Exposure guidelines (limit values) Engineering controls to minimize hazards Personal protective equipment (respiratory, hand, eye, skin and body protection) General hygiene	General applicable control measures Appropriate engineering controls and work practices Protective measures during maintenance and repair Personal protective equipment Permissible exposure levels, threshold limit values listed by OSHA, ACGIH, or established company limits
9. Physical and chemical properties	Appearance (physical state, color, etc.) 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, density Relative density Solubility(ies) Partition coefficient: n-octanol/water Auto-ignition temperature Decomposition temperature	Appearance (physical state, color, etc.) 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, density Relative density Solubility(ies) Partition coefficient: n-octanol/water Auto-ignition temperature Decomposition temperature	Appearance (color, physical form, shape) Odor/odor threshold Physical state pH Melting/freezing point [specify which] Initial boiling point and boiling range Flash point Evaporation rate Flammability (solid, gas) Upper/lower flammability or explosive limits Vapor pressure, density Specific gravity or relative density Solubility(ies) [specify solvent, e.g., water] Partition coefficient: n-octanol/water Auto-ignition temperature Decomposition temperature Other relevant data	Characteristics of hazardous chemicals, such as vapor pressure and density Physical hazards, including the potential for fire, explosion, and reactivity
10. Stability and reactivity	Chemical stability Possibility of hazardous reactions Conditions to avoid (e.g., static discharge, shock or vibration) Incompatible materials Hazardous decomposition products	Chemical stability Possibility of hazardous reactions Conditions to avoid (e.g., static discharge, shock or vibration) Incompatible materials Hazardous decomposition products	Physical hazards Chemical stability Conditions to avoid Incompatible materials Hazardous decomposition products Possibility of hazardous reactions	Organic peroxides, pyrophoric, unstable (reactive) or water-reactive hazards Physical hazards, including reactivity and hazardous polymerization
11. Toxicological information	Concise, but complete, description of toxicological (health) effects and the available data used to identify those effects, including: Ô Likely routes of exposure (inhalation, ingestion, skin and eye contact) Ô Symptoms related to physical, chemical and toxicological characteristics Ô Delayed and immediate effects, plus chronic effects from short- and long-term exposure Ô Numerical measures of toxicity, such as acute toxicity estimates	Concise, but complete, description of toxicological (health) effects and the available data used to identify those effects, including: Ô Likely routes of exposure (inhalation, ingestion, skin and eye contact) Ô Symptoms related to physical, chemical and toxicological characteristics Ô Delayed and immediate effects, plus chronic effects from short- and long-term exposure Ô Numerical measures of toxicity, such as acute toxicity estimates	Toxicological information: human, animal, and in vitro data, SAR Acute dose effects: single/ short-term exposures (e.g., LD50, LC50). Repeated dose effects (e.g., NOAEL) Irritation/corrosivity Sensitization (skin and respiratory) Carcinogenicity Neurological effects Genetic effects (e.g., mutagenicity) Reproductive effects Developmental effects Target organ effects	See also Section 2 [Health hazards, including acute and chronic effects, listing target organs or systems, signs and symptoms of exposure, primary routes of exposure, if listed as a carcinogen by OSHA, IARC, NTP]
12. Ecological information	Ecotoxicity (aquatic and terrestrial, where available) Persistence and degradability Bioaccumulative potential Mobility in soil Other adverse effects	Ecotoxicity (aquatic and terrestrial, where available) Persistence/degradability Bioaccumulative potential Mobility in soil Other adverse effects	Ecotoxicity, acute and long-term (fish, invertebrates) Persistence/degradability Bioaccumulation/bioconcentration Mobility: air, soil, water Other adverse effects	No present requirements
13. Disposal considerations	Description of waste residues and information on their safe handling and methods of disposal, including any contaminated packaging	Description of waste residues and information on their safe handling and methods of disposal, including any contaminated packaging	Safe and environmentally preferred waste management of the material and/or its container Classification under applicable law	No present requirements, See Section 7
14. Transport information	UN number UN proper shipping name Transport hazard class(es) Packing group, if applicable Marine pollutant (Y/N). Special precautions that a user needs to be aware of or needs to comply with in connection with transport or conveyance either within or outside their premises	UN number UN proper shipping name Transport hazard class(es) Packing group, if applicable Marine pollutant (Y/N). Special precautions that a user needs to be aware of or needs to comply with in connection with transport or conveyance either within or outside their premises	Proper shipping name Hazard class(es) Identification number Packing group Hazardous substances Marine pollutants (Y/N) IMDG classification TDG classification ICAO/IATA classification RID/ADR classification	No present requirements
15. Regulatory information	Safety, health and environmental regulations specific for the product in question	Safety, health and environmental regulations specific for the product in question	U.S federal regulations International regulations U.S. state regulations	No present requirements
16. Other information	Other information, including information on preparation and revision of the SDS	Other information, including information on preparation and revision of the SDS	Label text Hazard rating and rating system Information on SDS preparation and revision Key/legend	Date of preparation of MSDS or date of last change
Source: Occupational Safety and Health Administration, A Guide to the Globally Harmonized System of Classification and Labeling of Chemicals (GHS), www.osha.gov/dsg/hazcom/ghs.html.