I want to defend the GHS -- mostly. At the end I'll say what I think is its biggest flaw. Full disclosure -- I was part of the ILO working group that wrote the hazard communication sections of the GHS.

The two great virtues of the GHS are, first, that it's an international system. I was also the chair of the workers group that negotiated, with employers and governments, Convention 170 on Safety in the Use of Chemicals at Work, in 1989-90. When it was adopted by the ILO Conference, a lot of governments said they could not establish a hazard communication system on their own, and did not want to choose between the different conflicting systems in North America, Europe, and a few other countries. We knew that the majority of workers around the world would never achieve the right-to-know until we had a globally harmonized system capable of adoption worldwide. And now we do. We still have to fight the battle country-by-country, but at least we now have something to fight for.

(Incidentally, the fact that the GHS is an internationally harmonized system is why the numbers denoting hazard categories are "reversed." There was no international consistency on the proper order.)   

The other great virtue is comprehensibility, through the use of pictograms and standardized warnings. To illustrate that, let me point to two pre-GHS MSDSs I received from one of our local unions for two identical products (ceramic fiber insulation) from two different manufactures. One MSDS said: "Note. This material has been associated with malignant and non-malignant neoplasms in experimental animals exposed via intraperitoneal installation. As this route of exposure does not mimic the human experience, the significance of this finding is uncertain." The other MSDS said: "Warning. Can cause cancer if inhaled." (Amusingly, the local union was much more leery of the first product. They knew how to deal with carcinogens, but they figured that if the first company went to the trouble of writing that kind of warning, the stuff must be really bad.)

As one of our union members said during the OSHA hearings that led to OSHA changing the Hazcom Standard to conform to the GHS, "We have the right to know. What we need is the right to understand."

The great defect of the GHS is that chronic toxicity, especially carcinogenicity, is determined by the "weight of the evidence," instead of the old U.S. Hazcom system, where one well-conducted study demonstrating the hazard was enough. This has led to all sorts of mischief. Several years ago, when the chemical industry was trying to prevent NTP from listing styrene as a carcinogen, I collected SDSs for styrene from different manufacturers. They were all over the map. Even worse, I found US, Canadian, European and Japanese SDSs from the same manufacturer which differed in whether styrene is a carcinogen. This is less of a problem in the US, where our contingent-fee tort system makes it extremely risky for a manufacturer not to disclose a hazard. But it illustrates that a GHS "weight of the evidence" determination isn't all that scientific.

Mike Wright   

Michael J. Wright
Director of Health, Safety and Environment
United Steelworkers
 
412-562-2580 office
412-370-0105 cell

"My friends, love is better than anger. Hope is better than fear. Optimism is better than despair. So let us be loving, hopeful and optimistic. And we'll change the world."
                                                                                                                                                                                        Jack Layton


 

-----Original Message-----
From: ACS Division of Chemical Health and Safety [mailto:DCHAS-L**At_Symbol_Here**PRINCETON.EDU] On Behalf Of Jeffrey R. Cogswell
Sent: Tuesday, June 11, 2019 10:35 AM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: Re: [DCHAS-L] What is happening to the GHS SDS?

Hello Everybody

I've been reading the threads about GHS SDS and wanted to share my observations.

It's good to know I'm not the only one seeing issues but I think one reason might be because of merger of some companies, especially Sigma and Millipore. It's interesting as I'm seeing more details for PPE to be worn but some chemicals that had warnings in older versions are now "NO GHS Hazards" or don't meet hazard reporting.

I wish there was access to all previous "versions" of SDS sheets especially from Sigma Aldrich.

I'm currently in the process of inventorying the entire campus and each chemical I barcode has an attached SDS in the system. In some cases I feel that an older version is better than the latest one and have opted to not update it. I have also set requests to companies asking for an SDS sheet because I couldn't find it online. After a long wait I'm given a MSDS with the M removed so I needed to find alternatives. 

The complete elimination of NFPA and HMIS I feel are not the best decision for SDS. Our inventory program uses NFPA for building fire codes and for training with our Fire Dept. incase of an accident in the lab. First responders still need these codes and I feel should be provided. These have been in the past but are disappearing from SDS.

All updated SDS from MillipreSigma are eliminating NFPA's and I've only been able to consistently find them at ThermoFisher.

Conflicting hazard information has always been an issue but I have a problem with eliminating safely information altogether, that has been previous available.

-Jeff Cogswell

-----Original Message-----
From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU> On Behalf Of Yaritza Brinker
Sent: Tuesday, June 11, 2019 9:41 AM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: Re: [DCHAS-L] What is happening to the GHS SDS?

Monona,

Even though GHS is really good, the reality is that NFPA and HMIS labels are easier for the common worker. If you are standing in a manufacturing plant looking at drums and totes of chemicals, then NFPA and HIMS labels are simply easier to read. Some employers choose to add an NFPA or HMIS label to their containers on arrival.

I'm personally partial to HMIS labels because it includes a letter for the PPE type required. This is a good reminder for people like myself who run different types of tests with a wide range of chemicals and therefore wide range of risks.

Thank you,

Yaritza Brinker
260.827.5402

-----Original Message-----
From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON..EDU> On Behalf Of DCHAS Membership Chair
Sent: Saturday, June 8, 2019 1:28 PM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: [DCHAS-L] What is happening to the GHS SDS?

** External Email **

From: Monona Rossol <actsnyc**At_Symbol_Here**cs.com>
Re: What is happening to the GHS SDS?

I'm hoping someone can tell my why, after we finally have a good system of describing acute and chronic toxicity with the GHS dose-response Categories, I'm suddenly seeing the misleading dumb old HMIS one number toxicity system showing up even on the new Sigma SDS for Cyrene.

This is really depressing.

Monona Rossol, Arts, Crafts & Theater Safety.

---
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