State law has also not caught up with the GHS.  For example, Florida statute requires that we are in compliance with NFPA codes.  We are currently required to comply with the 2004 edition of NFPA 45.  For toxic gases, we determine if storage must be in an exhausted cabinet based on the NFPA health rating.

Janice Dodge

Laboratory Safety Officer

Florida State University

850-644-8916

I think one thing that this opinion does not take in to consideration is the HMIS III system, which is pretty much the same as NFPA 704, i.e.., completely opposite of the new GHS.  And that information is designed for the user, not firefighters.  So there are plenty of opportunities for confusion.  Not sure how that is going to be resolved. 

Jay Skarda
Director of Safety & Security
National Jewish Health

From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**MED.CORNELL.EDU] On Behalf Of Steve McLean
Sent: Thursday, June 06, 2013 12:19 PM
To: DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU
Subject: Re: [DCHAS-L] NFPA and OSHA, Harmony?

Keep in mind that the NFPA diamond is designed for FIREFIGHTERS, NOT chemists and laboratory personnel.  In most cases, a firefighter does not care about the exact value of the LD₅₀.  Water is toxic in a sufficiently high dose, but in a fire situation a firefighter is going to consider it a “0” – no health hazard – regardless of the amount that is present.

As a chemist who spent 12 years on a professional industrial firefighter crew, I can tell you that most firefighters care about the following: Is it highly flammable or not?  Is it water-reactive or not? Is it a serious health hazard or not?  Is it reactive or not?  If the answer is “not”, then a ZERO makes perfect sense.

Monona is correct: “We have a real chance here to finally teach people something real and useful in hazcom.  Let's not confuse the issue with the NFPA diamond.”  My translation: “We need to teach people about the hazards, but we need to make sure people know the difference between GHS and NFPA so they don’t confuse them.” 

We should allow GHS to teach us about Hazcom, but we should also allow the (unaltered) NFPA diamond to provide the BASIC information that is needed by firefighters.  If you cannot tell the difference between a NFPA diamond  and  a GHS pictogram with its associated class and category, regardless of their different scaling system,  then you should not be working with hazardous materials.

*******************

Steven J. McLean, CHMM

Laboratory Safety Manager

Risk Management - 241 FB

Office: (801) 422-6879

stevemclean**At_Symbol_Here**byu.edu

From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**MED.CORNELL.EDU] On Behalf Of Monona Rossol
Sent: Thursday, June 06, 2013 11:05 AM
To: DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU
Subject: Re: [DCHAS-L] NFPA and OSHA, Harmony?

Mark Ellison <mellison**At_Symbol_Here**sachsco.com>

Subkect: NFPA and OSHA, Harmony?

Thought I would share this with the group.  Interesting…

http://www.nfpa.org/publicJournalDetail.asp?categoryID=2915&itemID=62587&order_src=C246&cookie%5Ftest=1

Mark Ellison

Assistant Vice President-Safety Director

Sachs Electric Company

St. Louis, Missouri

The key quotes from the article inlcude:

One result of this collaboration is that OSHA does not see any reason for NFPA 

704 to be revised in order to correspond with the GHS category numbering...

...

For now, NFPA and OSHA are working to ensure that the two systems can 

effectively work together without significant change. Going forward, experience 

from full implementation of the GHS system may demonstrate a need for slight 

changes to NFPA’s system, but without the expectation that it would ever be 

eliminated.

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