Approaches to Classification When GHS Is Unclear
June 1 marks the end of the transition period for companies to convert all of their safety data sheets labels to meet the GHS standard for communicating hazards. For years, product stewards have been working through the transition period to correctly classify their products.
“There's not a lot of guidance out about how to apply a lot of the criteria of GHS, and how to correctly classify products that sometimes don't fit exactly into the mold, so we've all struggled on our own and sometimes with colleagues in discussions about how to correctly address these issues,” says Denese Deeds, senior consultant for Industrial Health & Safety Consultants.
For instance, Deeds ran into one case where a toxic material was included in an aerosol. Normally, the material was solid at room temperature, but in this product it was immersed in a toxic solvent base and released as a spray. “Now how do I classify that? Is it a vapor? Is it a dust/mist? Is it a combination of both? Should we be adding it together? Should we be evaluating it separately,” she asks. “There's no guidance in the GHS about that. So these are the things that we've had to figure out on our own, with an approach that we think makes sense.”
Another difficult issue is when there are reactions in the process. Faced with similar situations, some people might test their mixtures. Others might get their chemists together and seek to identify the reaction products, then seek existing data on which to base their classifications. Without guidance, different companies will take different approaches. “The point isn’t to underclassify products,” says Deeds. “We're trying to do it right, but there are no rules about these situations. Nobody writing the system anticipated that these kinds of products exist.”
To find common ground, Deeds will co-present GHS Implementation - The First Wave After the Tsunami - The Work Is Just Beginning, a session at Stewardship 2015. “We want attendees to take some topic areas of particular concern, to work in small groups, and discuss the challenges and their innovative approaches to solving problems. Then, report back to the group as a whole,” says Deeds. “If we bring people who have been doing this together to discuss some of these issues, we can learn from each other.”