Session No.

521

Using GHS Classifications and Chemical Data to Reduce Risk

in the Workplace
R. Scott Williams
Director of Sales
SiteHawk
Smyrna, TN

Introduction
A common theme in the Best Practices Arena has been found for many years across most
manufacturing vertical markets using chemicals in the workplace (Automotive, Chemical,
Energy, Oil & Gas, Pharmaceutical, Food & Beverage, etc.) . The risk involved in the use,
handling, and disposal of chemicals along with the potential exposure scenarios are generally the
foundation of those Best Practices. Taking a proactive versus reactive approach has always been
more difficult and often unattainableie, understanding risk and actively working to reduce it
based on key, measurable criteria.
In the past few years, one of the most significant legislative changes related to the method
of classifying and communicating chemical hazards has swept the world, most recently here in
the United States. The adoption of the Globally Harmonized System (3rd Edition) into OSHAs
1910.1200 regulation in March of 2012 may be the most single impactful regulation since the
original passage of the Hazcom regulation.
The Globally Harmonized System (GHS) brought about major changes in the way
chemicals are classified and how those hazards classifications are communicated to anyone who
may be exposed to them.
The implementation of Chemical Management Best Practices generally focuses on the
minimization, handling, storage, and/or disposal of hazardous chemicals. Lets turn the focus to
the less commonly used, but even more effective principal of Risk Reduction related to the use of
chemical hazards in the workplace. The logical next step is to review how the methodology of
GHS classifications will positively impact the Safety, Environmental, and Health professionals
ability to understand, communicate, and reduce the risk of the use, hazardous chemicals. This
paper will explore the adoption of GHS, the areas GHS information will support a successful Risk
Reduction Best Practice, and how to use this information to reduce your Chemical Hazard
Footprint.

Chemical Hazard Risk Reduction Starts with Information

Understanding the health, physical, and environmental hazards of a hazardous material is the
major structural element needed for a successful a Risk Reduction Best Practice. Lets call this
plan the Chemical Hazard Footprint Reduction Plan. Unfortunately, over the years, the
information necessary for understanding these hazards has been at best, hard to obtain; at worst;
inconsistent, unavailable, and unclear!
The hazards of a chemical can generally be defined into one of three areas:
1. Health Hazards
2. Physical Hazards
3. Environmental Hazards
Each of these areas should be considered when creating your plan for risk reduction. Each of
these hazards are defined by very specific rules by regulatory bodies who have adopted GHS-not
only for the type of hazard but, even more importantly, for the severity of the hazard. The
combination of the hazard classifications and the category (severity) will allow the Safety
Professional to understand the Risk associated with the use, handling, and disposal of the
hazardous material.

The SDSWill This Be Your Number One Source of Hazard

Information?
For those of you seeing the term SDS in print and correcting it mentally to MSDS, I understand
completely! One of the key changes related to chemical hazard information is the renaming of the
Material Safety Data Sheet to Safety Data Sheet. Even more significant, are the requirements of a
specified format (16 sections, in a required order), and the re-classification of the hazards of
every hazardous material according to very specific rules. These rules, adopted from the 3rd
Edition of the Purple Book. (GHS, 3rd Edition, 2009) are the keys to understanding the hazards
of material and to minimizing your Chemical Hazard Footprint. In the past MSDSs were of an
inconsistent format with even more inconsistent content. The incorporation of rules by OSHA
into 1910.1200 is putting an end to the inconsistent format and much of the inconsistent content.
It is important to note, that due to the phased timeline for implementation, both the SDSs format
and content are not required until June 1, 2015 and so MSDSs and SDS formats/content are
currently in circulation and will be for the near future.
The specified format has been widely distributed so for the purpose of this discussion,
we are going to focus specifically on the content being provided in Section 2 of the SDS. Section
2 is named Hazard Identification and does exactly thatprovides pictograms, signal words,
and hazard and precautionary information that can form the basis for understanding the risk
associated with the hazards of this product. These elements, when combined, give the reader of
the SDS the necessary understanding of the hazards, their severity, and statements on how best to
minimize or prevent adverse effects resulting from exposure to a hazardous chemical.
The terms Pictogram, Signal Word, Hazard Statement, and Precautionary
Statement are each defined in the Purple Book and have been carried over into OSHAs
adoption of GHS into the 1910.1200 regulation. Each of these elements should be considered
when understanding the hazards of the materials and used when creating your Chemical
Hazard Footprint Reduction Plan.

There are 9 pictograms, each designed to reflect specific hazards. While OSHA has made
the Environment Pictogram Non-Mandatory (Aquatic Toxicitiy), it should be noted that it is
required in many adoptions of GHS by other regulatory agencies and is often seen on SDSs that
have this hazard, especially if being sent to Europe.

The other Pictograms and their Hazards are shown here:

There are only two signal words: Warning and Danger. I heard an excellent Toxicologist
once use the phrase they threw Caution to the wind in reference to the previous ANSI signal
word that is no longer viable under this standard! These signal words help define the severity of
the hazard and when coupled with the Hazard and Precautionary Statements, provide a portion of
the baseline for measuring risk. Note that the absence of a signal word does NOT mean there are
no hazards associated with the material.
There are two additional elements to consider for creating a Chemical Hazard Footprint
Reduction Plan are the Hazard Statements and Precautionary Statements.

The Hazard Statements consist of the specific phrases assigned to a hazard class and
category that describes the nature of the hazard(s) of a chemical including, where appropriate, the
degree of hazard.
The Precautionary statements are defined as the phrase(s) describing recommended
measures that should be taken to minimize or prevent adverse effects resulting from exposure to a
hazardous chemical, or improper storage or handling. There are 4 types of Precautionary
statements:

Prevention
Response
Storage
Disposal

Note that these statements indicate not only the nature of the hazard, but the severity. This
is included as a Category, which ranges from 1 to 5, with 1 being the most severe, and 5 being the
least severe.
Each of these elements should be utilized when considering the chemical hazard footprint
of a facility. With this new regulatory requirement in which manufacturers must use specific rules
to define the hazards of the material, the Safety Professional can now more readily and accurately
determine which materials can provide the greatest impact to a risk minimization plan.
Understanding your Chemical Hazard Footprint is the first step to minimization.

Below are two tables, the first consisting of the worst-case or most hazardous
statement for each health hazard found in the adoption of GHS; the second consisting of
the worst-case or most hazardous statement for each physical hazard listed.

Table 1: Health Hazard Statements- Most Hazardous

Code

Health Hazard Statement

Hazard Class
(Appendix)

HazCat.

H300 Fatal if swallowed

Acute toxicity, oral (A.1)

1, 2

H310 Fatal in contact with skin

Acute toxicity, dermal (A.1)

1, 2

H330 Fatal if inhaled

Acute toxicity, inhalation

(A.1)

1, 2

H314 Causes severe skin burns and eye damage

Skin corrosion/irritation (A.2)

H318 Causes serious eye damage

Serious eye damage/eye

irritation (A.3)

H317 May cause an allergic skin reaction

Sensitization, skin (A.4)

1, 1A, 1B

Sensitization, respiratory
(A.4)

1, 1A, 1B

H334

May cause allergy or asthma symptoms or

breathing difficulties if inhaled

May cause genetic defects (state route of

H340 exposure if no other routes of exposure cause the Germ cell mutagenicity (A.5)
hazard)
H350

May cause cancer (state route of exposure if no

other routes of exposure cause the hazard)

May damage fertility or the unborn child (state

H360 specific effect if known)(state route of exposure if
no other routes of exposure cause the hazard)
Causes damage to organs (or state all organs
H370 affected if known) (state route of exposure if no
other routes of exposure cause the hazard)
Causes damage to organs (state all organs
affected if known) through prolonged or
H372
repeated exposure (state route of exposure if no
other routes of exposure cause the hazard)
H304 May be fatal if swallowed and enters airways
na

May displace oxygen and cause rapid

suffocation

1A, 1B,
1C
1

1A, 1B

Carcinogenicity (A.6)

1A, 1B

Reproductive toxicity (A.7)

1A, 1B

Specific target organ

toxicity, single exposure
(A.8)

Specific target organ

toxicity, repeated or
prolonged exposure (A.9)

Aspiration hazard (A.10)

Simple Asphyxiant

na

Table 2: Physical Hazard Statements- Most Hazardous

Code

Physical Hazard Statement

Hazard Class (Appendix)

Hazard Cat.
Unstable
explosive

H200 Unstable explosive

Explosives (B.1)

H220 Extremely flammable gas

Flammable gases (B.2)

H222 Extremely flammable aerosol

Flammable aerosols (B.3)

Oxidizing gases (B.4)

H270

May cause or intensify fire;

oxidizer

Contains gas under pressure;

H280
may explode if heated

H224

Gases under pressure (B.5)

Extremely flammable liquid and

Flammable liquids (B.6)
vapor

H228 Flammable solid

Flammable solids (B.7)

Compressed
gas
Liquefied gas
Dissolved gas
1
1, 2

H240

Heating may cause an

explosion

Self-reactive chemicals (B.8); and

Organic
peroxides (B.15)

H250

Catches fire spontaneously if

exposed to air

Pyrophoric liquids (B.9); Pyrophoric

solids (B.10); Pyrophoric gas

H251 Self-heating; may catch fire

Self-heating chemicals (B.11)

In contact with water releases

flammable
H260
gases, which may ignite
spontaneously

Chemicals which, in contact with

water, emit flammable gases (B.12)

Oxidizing liquids (B.13);

Oxidizing solids (B.14)

Corrosive to metals (B.16)

H271

May cause fire or explosion;

strong oxidizer

H290 May be corrosive to metals

na

May form combustible dust

concentrations in air

Combustible dust

Type A

na

Incorporating Hazard Classification Information into Your Risk

Reduction Plan
A proactive approach to risk reduction is always effective. There are three suggested elements to
implementing a proactive approach:

1. Insure you have an effective chemical approval process to know which chemicals are
being brought into the workplace
2. Define the level of risk you are willing to not allow into the workplace
3. Leverage the ongoing updating of SDSs to review existing chemicals in the workplace over
the next three years to find areas for reducing your chemical hazard footprint (reduced risk).
An effective chemical approval process includes the appropriate personnel in the review
cycle, is easily modified as the work environment or personnel change, and is a closed loop.
Being able to modify the questions needing answered on the form, including the right technical
staff, and notifying the requestor of the decision are all important elements.
The questions being asked should be directly related to the level of risk and the information
being reviewed by the technical staff (EHS personnel). For example, determining that materials
that materials with the Irritation pictogram, with the Hazard Statement of H314 (Causes Skin
Burns and Eye Damage) categories 1A, 1B, 1C will not be allowed into the facility without very
specific training, handling, and disposal process implemented is a good example of the level of
risk that can more easily be determined under GHS.
The risk determination can be directly related to your operations, and the chemicals
necessary for operations. Once the baseline is determined for new materials entering the
workplace; a secondary baseline can be created for those already existing in the workplace. The
process for gathering the information for existing chemicals can seem daunting, but over time
will be worth the effort. Using this to set Key Performance Indicators; for example, reducing
Health and Physical hazards related to chemicals in the workplace by 5% next year can produce
many benefits.
As the United States moves closer to full implementation of GHS, the consistent message
will become clearer and more readily available. The short term pain of updating all MSDSs to
SDS and the handling and communication of the newly defined hazards downstream is
significant, however, the long term gain of being able to determine risk levels and use the more
consistent data found on the SDS will far outweigh this. Creating a risk matrix which consists of
those elements defined by GHS (Signal Words, H&P Statements, and Classifications) and
comparing this to the more hazardous materials employees want to bring in or are used in your
workplace will allow your organization to provide a safer, healthier, work environment which has
been proven over and over to reduce costs across the organization.

Bibliography
Occupational Safety & Health Administration (OSHA). 2012. 29 CFR 1910.1200, including
Appendices.
United Nations. 2009. Globally Harmonized System of Classification and Labelling of
Chemicals (GHS). 3rd Revised Edition.