Executive Summary... 2 The Step-by-Step Process for Classifying Hazards... 4 Understanding GHS Hazard Classifications: Classes & Categories.. 6 Hazard Classes and their Applicable Categories... 7 Physical Hazards... 7 Health Hazards... 8 Environmental Hazards... 9 Essential Step: UNECE Classification Summary table... 9 Classification of Mixtures... 9 How to Communicate Hazards: Hazard Statements... 11 What if a Hazard is Not Classified under GHS?... 12 Pyrophoric gases (in addition to the Flame GHS pictogram)... 12 Simple asphyxiants... 13 Combustible dusts... 13 The Hazards not otherwise classified Category... 13 The Most Effective Way to Classify Hazards... 14 How to Ensure Your SDSs & Labels are Accurate... 16 Resolving Conflicting Data: Sulfur Case Study... 18 Finding Tools for Accurate & Reliable Authoring... 25 1

The Globally Harmonized System (GHS) for Safety Data Sheets (SDSs) and Labels has gained huge mindshare among facility owners/operators and safety & environmental managers in the last 12 months. Now that the North American Occupational Health and Safety regulators have committed to adopting the GHS standards for chemical hazard communication by 2015, the clock has started ticking for businesses to get their affairs in order. Under the new Globally Harmonized System (GHS) of SDS and Label authoring, chemical manufacturers, importers, and distributors are required to update the method they classify and communicate the hazards of their products. As a manufacturer, importer, or distributor you ll need to know the new way to classify hazards. You ll also need to know which hazards are classified under GHS guidelines and which hazards are not so you can properly address them in Section 2 of your SDS and on your labels. This guide will explain the process for accurately classifying a material for the new GHS-compliant SDS or label step by step. You should use this guide in tandem with the official GHS guide the Purple Book which you can access for free online at: http://www.unece.org/trans/danger/publi/ghs/ghs_rev03/03files_e.html 2

Inside this guide you ll learn: The step-by-step process for classifying a chemical hazard The logic behind GHS categories and classes How hazard and precautionary statements are used for SDSs and Labels The most effective way to become GHS compliant How to ensure your SDSs are accurate and reliable 3

Under the GHS, hazards are subdivided into class and category. There are 3 classes: health hazards, physical hazards, and environmental hazards. Each of these 3 classes are divided into hazard categories (for example, a material might fall under the physical hazard class and be in the flammable category). Class describes the nature of the hazard and category the type and degree of the hazard. A material can have several hazard categories for each class. It s possible for a single material to be flammable, an eye irritant, and acutely toxic. Section 2 of the new GHS-style SDS and Label requires you to list hazard statements that are related to each applicable class and category. Hazard statements are the standardized statements that replace the OSHA R-Phrases and describe the hazards for anyone using or transporting that material. For more information on Hazard Statements, read section How to Communicate Hazards: Hazard Statements. But first you ll need to follow the step-by-step process to determine hazard class and category. 4

The steps to classify a hazard: 1. Identify the relevant chemical data for your material that relates to potential hazards (what chemicals are in the material? Are any components toxic? Reactive?). If you aren t sure where to start, consider which hazards your materials present under the old OSHA Hazard Communication standards. 2. Use the GHS guidelines in the Purple Book to determine if the material falls under one or more hazard class (physical, health, environmental). 3. Test your chemicals or consult scientific evidence/publications to determine how your material s chemical components relate to classification guidelines. 4. Identify each of the hazard classes that apply to each chemical in your material. 5. Identify the applicable hazard categories within each class applied to each chemical and identify its severity. Ultimately, classifying your material comes down to knowing the exact chemical makeup of that material, and being able to apply the Purple Book s guidelines to each chemical to first determine class, then category. Also note that you are not required to test chemicals for the purpose of hazard classification. You may instead consult scientific literature to assess whether your material meets the OSHA definition of a hazardous chemical. For example, the Environmental Protection Agency s chemical databases can be used in place of in-house lab testing. Make sure the sources you use are reliable. 5

GHS uses three hazard classes: Health hazards, Physical hazards and Environmental hazards. Health hazards present dangers to human health (i.e. breathing or vision) while physical hazards cause damage to the body (like skin corrosion). There are 16 physical hazards and 10 health hazards: each hazard is then further divided according to different severity levels. Environmental hazards refer to acute and chronic aquatic toxicity, but aren t required by OSHA. Chemical manufacturers, importers, and distributors are required to classify their chemicals using the updated HazCom 2012. HazCom 2012 provides specific criteria to address physical hazards, health hazards and the classification of chemical mixtures. It s important to note, the HazCom 2012 categories are similar yet contradictory to the HMIS/NFPA ratings: GHS 1 4 rating system ranks 4 as the least severe while NFPA s rank 4 is most severe. This inverse rating system has created some concern, however OSHA has indicated that the GHS numbers are for hazard classification purposes and do not reflect the rating of the hazard itself. Additionally, the GHS number will not be required on labels. Nevertheless, NFPA and OSHA have worked to produce a quick card to clarify the issue as much as possible. 6

The following tables can be used as a quick reference once you ve determined a material s hazard classification. Each class has one or more associated categories. Once you determine class and category you ll have the information you need to assign signal words, pictograms, and precautionary statements. Physical Hazards Hazard Class Explosives Associated Hazard Category Divisions 1.1-1.6 (with 1.1 being the most hazardous, 1.6 the least hazardous) Flammable gases Categories 1 and 2 Flammable aerosols Categories 1 and 2 Oxidizing gases Category 1 Gases under pressure 4 Groups include: Compressed gas, Liquefied gas, Dissolved gas, and Refrigerated liquefied gas Flammable liquids Categories 1-4 Flammable solids Categories 1 and 2 Self-reactive substances Types A-G Pyrophoric solids Category 1 Pyrophoric liquids Category 1 Self-heating substances Categories 1 and 2 Substances which in contact with Categories 1-3 7

water emit flammable gases Oxidizing liquids Categories 1-3 Oxidizing solids Categories 1-3 Organic peroxides Types A-G Substances corrosive to metal Category 1 Health Hazards Hazard Class Acute toxicity Associated Hazard Category Categories 1-4 (with 1 being the most dangerous) Skin corrosion Categories 1A, 1B, 1C, and 2 Skin irritation Categories 1A, 1B, 1C, and 2 Eye Effects Sensitization (Skin or Eye) Categories 1, 2A, and 2B Category 1A and 1B Germ cell mutagenicity Categories 1A, 1B, and 2 Carcinogenicity Categories 1A, 1B, and 2 Reproductive toxicity Target organ systemic toxicity: single and repeated exposure Categories 1A, 1B, 2, and additional category for effects on or via lactation Single: Categories 1-3 Repeated: Categories 1 and 2 Aspiration toxicity Category 1 and 2 8

Environmental Hazards Hazard Class Associated Hazard Category Acute Aquatic Toxicity Categories 1-3 Chronic Aquatic Toxicity Categories 1-4 The above tables provide a brief summary of the classification/category relations. However, the United Nations Economic Commission for Europe has compiled a comprehensive list of classification and categories which should be used to verify your classifications. Access it for free online here. This document also includes decision flow charts and numerical limits/thresholds that will be essential if you are required to author GHScompliant SDSs and/or labels. The GHS classifies mixtures using a tiered approach. To classify your mixtures you should use available testing data for the mixture itself along with the GHS classification guidelines. An exception to this is if your mixture is a carcinogen, a mutagen, or a reproductive toxin where classification may be based on the strength of evidence and modified on a case-by-case basis. For untested mixtures the GHS suggests applying bridging principles with similar tested mixtures or using the cut-off approach with the values described in the 9

specific end point. Bridging principles exist for Dilutions, Batching, Concentration of Highly Toxic Mixtures, Interpolation within One Toxic Category, Substantially Similar Mixtures and Aerosols. More information about the GHS bridging principles and Mixture classification can be found online here. 10

Once you have classified and categorized your substances and mixtures you will be able to apply the correct hazard statements to your Safety Data Sheets and Labels. GHS Hazard statements were designed to replace OSHA R-Phrases. Each hazard statement has a specific hazard code, although your SDSs and Labels must include the entire statement and not simply the code number. This ensures that anyone reading the document knows exactly what to expect immediately without having to refer to a long list of codes. Section A3.1.2.1 of the UNECE document explains the codification of the hazard statements: 1. Each code begins with the Letter H for Hazard Statement 2. The first number designates the type of hazard the hazard statement is assigned a. 2 = physical hazard b. 3 = health hazard c. 4 = environmental hazard 3. The second and third numbers refer to the intrinsic properties of the substance 4. Some hazard codes and statements can be combined/ conjoined using a + which means or 11

For example, the hazard code H200 refers to an unstable explosive. It s clear from the first letter of the code, 2, that the explosive property of the material is a physical hazard. Take a look at all the hazard statements here. Some hazards are not classified under GHS, but that doesn t mean they can be ignored. These types of hazards are divided into 2 groups: Pyrophoric Gases, Simple Asphyxiants, and Combustible Dusts ; and Hazard not otherwise classified. Pyrophoric Gases, Simple Asphyxiants, and Combustible Dusts These hazards have their own unique requirements and generally do not have any specific GHS pictograms associated with them (the one exception being pyrophoric gas which can use the flame GHS pictogram). Nevertheless, they must still be included under Section 2 in the SDS and on the label as follows: Pyrophoric gases (in addition to the Flame GHS pictogram) Signal word - Danger Hazard statement - Catches fire spontaneously if exposed to air 12

Simple asphyxiants Signal word - Warning Hazard statement - May displace oxygen and cause rapid suffocation Combustible dusts Signal word - Warning Hazard statement - May form combustible dust concentrations in the air Some materials may have hazards not classified by the Globally Harmonized System that cannot be defined as Pyrophoric Gases, Simple Asphyxiants, and Combustible Dusts. If a chemical product contains a Hazard Not Classified by the GHS (HNOC), it must be addressed in section 2 of the SDS and may or may not be included on the label under Supplemental information. 13

The Globally Harmonized System offers manufacturers, importers, and distributors a better way of understanding and communicating information about their materials. However, this shift will also present a challenge because the systems most businesses have in place will need to be updated. Classifying a single material can require a great deal of testing and research, and uses an unfamiliar set of thresholds and requirements. When it comes to the Globally Harmonized System (GHS), having information is power. Information is what will power your ability to classify materials properly, author accurate Safety Data Sheets (SDSs) and labels, train your staff how to understand chemical hazards, and implement the GHS standards as efficiently as possible. However, right now there is a glut of information about the GHS and GHS classifications - the rabbit hole of information you could read is endless and it s possible you might find yourself feeling more confused and conflicted than when you started. In fact, there is so much information available online right now that even some regulatory bodies and big businesses have their own unique interpretation of how the GHS Classification system works. Many companies are looking for ways to automate this GHS classification process using an electronic system that already has the new GHS rules built in. Rather than building a whole new set of internal chemical management guidelines under a tight deadline, using GHS SDS/Label authoring software 14

can ease the transition by automatically classifying your materials while you properly implement and master the GHS. That way you ll have accurate and compliant GHS documents, you ll save time, money, and avoid stress, and your transition to GHS will be smoother and more successful. Mistakes in your SDSs or labels could have significant consequences but are generally easily avoided with a little research. 15

Reliability is crucial when you re assessing information about your chemicals and classifications so that you can author GHS-compliant labels and SDSs. Using the wrong information for the situation could result in an inaccurate and dangerous SDS. The best method to ensure accuracy and reliability in any GHS-compliant material you produce is to take a two-tiered approach: first have the most accurate raw chemical data about your materials and, second, reference and compare multiple regulatory resources before making any final determinations. The key here is balance: taking information from one regulatory list to make your classifications leaves you vulnerable to incorrect assumptions, but consulting every available list for each chemical will take days to author a single SDS. What works best is consulting around three to five trustworthy sources, and using those same sources each time. The GHS doesn t require chemical manufacturers or distributors to test each and every chemical and material that they ship or sell, instead allowing them to use industry publications that review lab testing data that others have performed. If you re using published testing data it is especially important that you ensure the publication is credible. Although you may find credible chemical data through your searches, the best sources are those sanctioned by or curated by an official government or regulatory body. For example, the Environmental Protection Agency (EPA) collects reliable data on chemical toxicity and environmental impacts. 16

Most importantly, always refer back to the United Nations Purple Book, which is the official guideline to GHS implementation. You can order a physical copy for your business online, or read it for free online here: http://www.unece.org/trans/danger/publi/ghs/ghs_rev03/03files_e.html For example, when ERA Environmental Management Solutions authors SDSs and labels for chemical materials, we use at least four different databases of chemical determinations, chemical testing data, and regulatory body finds per chemical. ERA also breaks each material down into its exact chemical components so that SDSs have all the information they need. Using the wrong information for the situation could result in an inaccurate and dangerous SDS. Even the most common chemicals should be subject to extra research. Stopping at just one source of chemical information for any material when authoring your SDSs and labels is bad practice, even if it s from a source you generally trust, like the Environmental Protection Agency. There is so much information available about the GHS classification system that there s debate about certain chemicals even between regulators and experts. 17

ERA Environmental Management Solutions experienced this scenario firsthand when our team of experts went to work researching how to properly classify materials containing sulfur. Although data from the GHS guidelines classifies sulfur as having particular hazards, regulators in North America classify it as also having a different set of hazards. Which should you use? Which governing body is correct? The case study presented below answers these questions: The Chemical: Sulfur. Sulfur is an abundant, multivalent non-metal. It occurs naturally as a pure element. Today, most of elemental sulfur is produced as a by-product of removing contaminants from natural gas and petroleum. The element is commercially used in fertilizers and in the production of sulfuric acid. The Problem: According to the Classification Labelling and Packaging (CLP) regulation, sulfur is classified as Skin corrosion/irritation Category 2. Upon further research, our expert scientists found that sulfur should also be classified under Acute Toxicity Inhalation Category 4, Acute Toxicity Dermal Category 5, and Acute Toxicity Oral 5 in addition to its CLP classification. Additional but less affirmative evidence also suggests that sulfur can be classified as an Eye Irritant Category 2 and a Flammable Solid Category 2. 18

The Sigma- Aldrich SDS for Sulfur indicates that under OSHA and WHMIS, sulfur is classified as a flammable solid Category 2. However, under the CLP, this categorization is not specified. GHS classification criteria can be used to reclassify chemicals on lists, if desired. Existing lists could be used in conjunction with the GHS to promote harmonization, according to OSHA. Even though the GHS Classification specifies that Category 2 skin irritants are not necessarily eye irritants, this is subject to debate. Table 3.2.5 from the GHS Purple Book shows that only category 1A, 1B and 1C are linked to eye damage because they are corrosive. Though not specified in the GHS guidelines, it is certainly possible that a chemical that causes a simple skin irritation can also cause an eye irritation. There is some uncertainty with regards to the eye irritant potential and flammability of sulfur. However, this case study draws attention to the fact that Hazard classification is not always black and white. And sometimes, companies 19

need to make the most conservative judgment call based on the research available. The Solution: By researching multiple chemical and toxicological databases, including Sigma Aldrich and Rtecs, our scientists were able to gather and compare MSDSs to see how sulfur was classified. Additional GHS Classification information is presented below: SIGMA ALDRICH: MSDS for Sulfur: 20

RTECS database: Acute toxicity, Inhalation (Category 4) 21

Decision tree from GHS Purple Book (Pg. 127) 22

Key Take-away: Without proper cross-referencing, sulfur would have remained classified as a Category 2 Skin Irritant. While this is acceptable according to GHS, it does pose a risk to your employees. If you don t communicate all of the dangers your materials present, your staff may find themselves injured or at risk without the necessary information to protect themselves or treat the exposure. And it s your business that will be held responsible. A little extra research in to other chemical databases can better guarantee a safer work environment, and one that presents less risk to your productivity. When authoring your SDSs and labels, you must classify sulfur as a Category 2 Skin Irritant, but you should also classify it as an eye irritant and a flammable solid as well Acute Toxicity Inhalation Category 4, Acute Toxicity Dermal Category 5 and Acute Toxicity Oral 5. Include the GHS hazards statements, precautionary statements, pictograms, etc. This is the best choice as it will ensure you are compliant with the GHS, increase on-site safety, and make your work easier if OSHA decides to modify or reclassify sulfur in the future. Researching multiple sources and authoring the most comprehensive SDSs and Labels is important to your success, but it also requires a great deal of time and effort if you don t put a system in place to make the task more efficient. ERA s SDS authoring software system lets you author GHS compliant SDSs and Labels on the fly for any of your materials in just minutes - and it instantly references multiple databases to ensure you get the most reliable and comprehensive data 23

possible. As this case study shows, we take getting you the best information possible seriously. Raw chemical component data is the foundation of your SDSs and labels. If you know which chemicals make up your materials, you have the essential building blocks to classify your chemical hazards and assign proper precautionary statements. If you get your materials from a vendor and need to author labels for containers you use on site, take the extra step to ensure you are given reliable chemical component data from your vendors. Ideally, you should collect all your data from vendors electronically using a secure upload system to encourage higher quality data being shared with you. 24

Right now businesses have a lot of options when it comes to GHS implementation. Classifications can be done in-house, you can hire consultants to do your authoring for you, or you can use a GHS software platform to author and manage your SDSs and labels online. Regardless of which option you choose, it is essential that you assess their methodology for classifying material under the new GHS standards. How many sources do they reference when making a determination? How do they measure the reliability of those sources? Is there a dedicated research team knowledgeable about the many sources of information about the GHS? Look for a solution that pulls data from multiple sources, as this is the best way to guarantee accuracy in your SDSs and labels. Extensive library and testing research should be done on each chemical component to ensure hazard classifications are correct. Doing this in-house gives you complete control of how much research gets done, but also requires a far greater time investment. Using a GHS software platform like ERA s allows your authoring to rapidly crossreference multiple reliable sources, producing a SDS or label in just minutes. 25

About ERA Environmental Management Solutions ERA Environmental Management Solutions specializes in web-based SDS and environmental management software for manufacturing industries, including chemical manufacturing, automotive, and oil & gas. ERA s software combines more than 20 years of environmental compliance expertise with cutting-edge technology to provide environmental managers with the most accurate environmental and chemical data. ERA s authoring software specialists take pride in their chemical research; with over 120,000 chemicals in its Master Chemical List, ERA boasts thoroughly-researched and classified chemicals. ERA pulls data from multiple sources, as this is the best way to guarantee accuracy in your SDSs and labels. Extensive library and testing research should be done on each chemical component to ensure hazard classifications are correct. Doing this in-house gives you complete control of how much research gets done, but also requires a far greater time investment. Using a GHS software platform like ERA s allows your authoring to rapidly cross reference multiple reliable sources, producing a SDS or label in just minutes. If you would like to find out more about ERA s SDS Management Software solutions and how they can help you manage your facilities more efficiently and with less frustration, call us 1-866-492-6409 or visit Disclaimer: All information contained in this fact sheet is accurate as of May 2014. ERA accepts no liability for the content of this guidebook, or for the consequences of any actions taken on the basis of the information provided. To ensure the accuracy of the information provided, please contact your state or provincial regulator. For the most recent version of this document, please contact ERA at (514) 684-6408. 26