In addition to Monona's valid observations, I think it is useful to remember just where the system came from. Yes, many countries had signed on before the US got serious about the matter, but the US was represented in the development of the system from the beginning. Before there was GHS, however, there was the UN Recommendations for the Transportation of Dangerous Goods, which trickled down through the IATA, ICAO, IMO, international agreements, and national regulations, and which the world had been harmonizing on for several decades. This system has the numbering of 1 (most hazardous) through 3 (least hazardous, although still hazardous). The Committee of Experts that developed and periodically revises the UN Recommendations was expanded in number and scope for the specific purpose of developing and maintaining the GHS, and their work is clearly based on the kernel provided by the then-existing UN Recommendations, which are still in use for transportation of dangerous goods (hazardous materials).
When GHS was first published, I recall considerable publication about there having been intense discussion of whether the hazard numbering should be 0-4 (least to most) or 1-4 (most to least). But as the basis of the regime was a long established 1-3 (most to least) no one should be surprised at that scheme being adopted. The rest of the world was certainly much more familiar with that sequence than with the NFPA sequence.
Peter Zavon, CIH
Penfield, NY
PZAVON**At_Symbol_Here**Rochester.rr.com
From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU> On Behalf Of Monona Rossol
Sent: Friday, May 28, 2021 6:17 PM
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Subject: Re: [DCHAS-L] [DCHAS-L] EXTERNAL EMAIL: Re: [DCHAS-L] Pentadecafluorooctanoyl chloride.
Well, I might as well weigh in. I LOVE the new category numbering system because it is consistent with so many other European standards. It is our NFPA and other systems that I think are the outliers. Did you REALLY like the NFPA flammability standards? Those would cross a Rabbi's eyes. Give me plain old GHS 1,2,3,4.
And the pictograms are just an initial alert. Students just need to know they indicate you are not done until you read the rest.
Remember that the Purple books were developed by people from many countries including ours. We didn't see any of this as important until the EU gave us until June, 2015 to adopt the GHS or stop exporting to them. And by then, 162 other countries agreed. Our really useless MSDSs were the cause and someone finally call us out. And we got to see the first major change in an OSHA regulation done without 20 years of hand-to-hand combat between worker advocates and industry.
I love GHS (except for the weight of evidence on cancer rating) Monona
-----Original Message-----
From: Mayo, Bret <0000134e357a2939-dmarc-request**At_Symbol_Here**LISTS.PRINCETON.EDU>
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Sent: Fri, May 28, 2021 3:14 pm
Subject: Re: [DCHAS-L] [DCHAS-L] EXTERNAL EMAIL: Re: [DCHAS-L] Pentadecafluorooctanoyl chloride.
I think you hit the nail on the head below when you said, "- it all comes down to training." These students are required to take a training class that combines HazCom and GHS (one of several training modules they must complete) before they are ever allowed access to a lab. Clearly, some of the key concepts and definitions were missed, so we have a good bit of work to do to figure out why that happened and how to fix it. It was nevertheless frustrating to me that they chose to make important decisions based on cartoons instead of safety statements, SDS's, consulting with their Principal Investigator, or any of the myriad other available resources.
By the way, I am totally with you on the numbering system issues, too.
"Able to burn or corrode organic tissue by chemical action"
"Capable of destroying or eating away by chemical action : CORROSIVE"
"Any chemical substance that burns or destroys living tissue"
"Capable of burning, corroding, dissolving, or eating away by chemical action"
But from an EHS/waste perspective caustic refers specifically to alkaline or basic materials. Obviously, the correct way to address this would be to use the pH definitions instead - acidic and basic instead of using terms that can be easily confused with each other. That's one reason the NFPA came out against the word, "inflammable", which, while completely valid and equal to "flammable", confused a lot of people who figured it must mean "not flammable."
In the end, however, it all comes down to training. Incidents like this are great at showing us what we need to train better, and think of ways to make sure the message stays such as posters, charts etc.
My biggest GHS gripe is that the numbering system is completely backward from most other ranking conventions. In the NFPA/HMIS systems a higher number means a higher hazard, third degree burns are more serious than first degree etc. etc. But for GHS hazard classification, a low number is the higher hazard. Mind you, the whole idea of using numbers or symbols instead of (or in conjunction with) words is just insane.
I don't like the pictograms either. I was in favor of them when they first appeared, but no longer. One recent example underscores how pictograms have contributed to the "dumbing down" of some lab workers at the university where I work: We attach a Tyvek tag to our liquid waste containers so researchers can record what they put inside. One section of the tag is used to indicate the primary hazard class for the contents. We rely on that information to determine where the container should be stored when removed from the lab and relocated to an accumulation site. In one lab I noted that check marks were next to both "Caustic" and "Acidic". I called one of the grad students over to point out that the primary hazard class for the container could not be both Caustic and Acidic and if they were mixing the two waste streams in one container it might also be dangerous. He looked puzzled but nodded understanding and I left. A few minutes later he found me in the hall and told me I was mistaken and wanted to show me why. He and a colleague (these are both 2nd year grad students doing polymer synthesis) had produced two chemical containers (formic acid and potassium hydroxide) and the senior grad student pointed at the "Corrosive" pictogram on each and declared, "See? They ARE the same." I spent the next 10 minutes explaining the definitions and differences between the terms Corrosive, Caustic, and Acidic, and emphasized that they should actually read the warning information and not pay so much attention to the cartoons.
Associate Director of Environmental Health and Safety
Dept. 3300, PO Box 6050 / Fargo, ND 58108-6050
Office Phone: 701-231-6299
Good points Mike. I also really don't like the pictograms. Most are easily understood but some are not. I much preferred the warnings. The SDS is now challenging even for those with a high level of technical skill to interpret relative to the actual risks presented.
S.Z.. Mansdorf, PhD, CIH, CSP, QEP
Consultant in EHS and Sustainability
The GHS was a terrific step forward in three ways - comprehensibility, globalization (in that it provided a ready-made system for countries that could not develop their own), and trade. But it has a serious flaw compared to the original OSHA Hazcom standard. (Full disclosure - I was a member of the coordinating committee that designed the SDS and labeling systems.) For some endpoints, the GHS takes a "weight of the evidence" approach, whereas the old OSHA standard mandated that a single positive well-conducted study was enough to establish carcinogenicity, mutagenicity, etc. Weight of the evidence determinations can vary widely, and sometimes for reasons unrelated to the scientific evidence. We've seen wildly different SDSs for the same chemical. Sometimes the same manufacturer will classify the same chemical differently in different jurisdictions. Clearly, this is not a science-based decision.
This is less a problem in the USA than in some other countries, because the easiest way for a manufacturer to lose a big product liability case is to withhold information from users. Thank God for our contingent-fee tort system. But we've still seen plenty of discrepancies.
I'll leave to the lawyers whether OSHA could go back to the "one positive study" approach without running afoul of trade law. But even if they can't, they could make it harder for a classifier to ignore positive studies. One way would be to require a transparent, publically available analysis, disclosing the evidence relied on and the evidence rejected, for any "weight of the evidence" determination. Some of us discussed that possibility with OSHA during the Obama Administration, and some preliminary efforts were underway, but of course they ended in 2017.
Fortunately, OSHA's current Hazcom rulemaking provides a splendid opportunity to push this issue again. The initial comment period ended last week, but hearings are scheduled for September, so there will be plenty of chances for written and oral testimony and post-hearing comments. I know OSHA would welcome participation by members of the DCHAS.
"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."
> Requiring references is the norm in published scientific literature, why not this standard of quality and traceability in SDSs as a key source of information?
I think I can suggest the reason for this. The SDS did not begin existence as scientific literature, but as industrial safety information provided by the manufacturer for the _industrial_ user, and that in a much less formal era of the 1960s. There have been significant modifications since then but dragging it into the realm of scientific literature is clearly a herculean task still in progress and unlikely to be completed in the near future. That doesn't mean you should not continue to seek that level, but there is little point in being incensed about the SDS not being at that level now or soon.
I concur with the need for more clarity around sources of data reported in SDSs from manufacturers and chemical suppliers. Requiring references is the norm in published scientific literature, why not this standard of quality and traceability in SDSs as a key source of information?
Just a note about the Safety & Hazard information in PubChem - this is sourced from many different agencies and other entities. These sources are documented under each entry with a link back to the original source.
The corrosive GHS symbol included for Pentadecafluorotoctanoyl chloride is from ECHA, for example. Specifically the source is the ECHA C&L inventory database, which compiles classification and labelling notifications from a number of companies as reported to ECHA per the CLP criteria (EU regulation).
PubChem is a service from the National Library of Medicine that provides information from other authoritative sources as reported. The motivation is to provide a starting point and where to link to find further information. It is incumbent upon the user to determine what information and source is relevant for their needs. PubChem is not an official classification entity for GHS or any other status of chemical substances.
I hope this may help generally. As a volunteer curator with PubChem, I am happy to have ideas for additional data and information sources.
> >Could we have a webinar or discussion about the differences in SDS? I have faced those many times and depending on the manufacturer there are really big differences.
>
That would be a great topic to take up in a CHAS chat. We did begin this discussion in the March CHAS chat this year on Quality Data For Safer Experiments.q You can see the notes from this session at
http://dchas.org/2021/03/11/quality-data-for-safer-experiments/
However, a more focused discussion on assessing the fit of a SDS to answering a lab safety question would be a good topic for a group discussion. Do we have any volunteers to lead this discussion?
Thanks for this suggestion!
- Ralph
Ralph Stuart, CIH, CCHO
Environmental Safety Manager
Keene State College
603 358-2859
ralph.stuart**At_Symbol_Here**keene.edu
---
For more information about the DCHAS-L e-mail list, contact the Divisional membership chair at membership**At_Symbol_Here**dchas.org
Follow us on Twitter **At_Symbol_Here**acsdchas
--- For more information about the DCHAS-L e-mail list, contact the Divisional membership chair at membership**At_Symbol_Here**dchas.org Follow us on Twitter **At_Symbol_Here**acsdchas
