GHS / CLP Compliance

The Globally Harmonized System (GHS) for classification and labeling of chemicals provides a unified international framework for the creation of labels and data sheets. It is a uniform, logical approach to:

• Defining health, physical and environmental hazards
• Compare available chemicals data with defined hazards criteria
• Communicate hazard information and protective measures

The GHS is not a regulation or standard. It simply establishes agreed hazard classification and communications provisions. Countries that adopt the system will do so through their own regulatory procedures.

For labels and safety data sheets, the GHS provides a consistent set of:

• Symbols (pictograms) to convey the type of hazard
• Signal words to communicate the level of severity
• Statements to describe the nature of the hazard and recommended precautions

The prescribed symbols, signal words and hazard statements can be readily selected from Annex 1 of the GHS Purple Book. These standardized elements are not subject to variation and should appear on the GHS label as indicated in the GHS for each hazard category/class in the system.

More than $1.7 trillion worth of chemicals are produced globally every year, including $450 billion in the US. Their widespread use has given rise to sector-specific regulations of chemicals in transport, agriculture, trade and consumer products, among others.

By sharing information about hazardous properties and recommended control measures in a uniform way, we make it safer to produce, transport and use important chemicals.

The United Nations Economic and Social Council established committees to produce the GHS in 1999 and endorsed the system in 2003. The Sub-Committee of Experts on the Globally Harmonized System of Classification will:

• Be custodian of the GHS, managing and giving direction to the harmonization process
• Keep the system up-to-date and relevant
• Promote understanding and global use of the system, while also gathering feedback
• Give guidance on the interpretation and technical application of the system
• Prepare work programs and submit recommendations to the UN Committee of Experts on the Transport of Dangerous Goods and on the Globally Harmonized System of Classification and labeling of Chemicals

The GHS covers all hazardous chemicals. There are no complete exemptions from the scope of the GHS for a particular type of chemical or product. The term "chemical" is used broadly to include substances, products, mixtures, preparations, or any other terms that may be used by existing systems.

"Articles" as defined in the OSHA Hazard Communication Standard (HCS) (29 CFR 1910.1200), or by similar definitions, are outside the scope of the GHS. Chemical inventory (e.g., TSCA, EINECS, etc.) and chemical control requirements in various countries are not harmonized by the GHS. Classification in the GHS is criteria-based, not limiting coverage to a list that can become outdated. It is not anticipated that the GHS will develop or maintain an international classification authority or international classification list. Several countries currently maintain regulatory lists. GHS classification criteria can be used to reclassify chemicals on lists, if desired. Existing lists, such as those provide by organizations that evaluate cancer hazards, could be used in conjunction with the GHS to promote harmonization.

The need for GHS labels and/or MSDSs is expected to vary by product category or stage in the chemical's lifecycle, from research/production to end-use (see graphic below).

For example, pharmaceuticals, food additives, cosmetics and pesticide residues in food will not be covered by the GHS at the point of consumption, but will be covered where workers may be exposed (workplaces), and in transport. Also, the medical use of human or veterinary pharmaceuticals is generally addressed in package inserts and is not part of existing hazard communication systems. Similarly, foods are generally not labeled under existing hazard communication systems. The exact requirements for labels and MSDSs will continue to be defined in national regulations. However, national requirements are expected to be consistent with the detailed discussion of scope provided in Chapter 1.1 of the GHS document.

The GHS is a voluntary international system with no binding treaty obligations. To the extent that countries adopt the GHS into their systems, the regulatory changes would be binding for covered industries. For countries with existing systems, it is expected that GHS components will be applied within the existing framework/infrastructure. For example, exceptions and exemptions found in existing regulations would not be expected to change (e.g., transportation of limited quantities).

However, the specific hazard criteria, classification processes, label elements and MSDS requirements within an existing regulation will need to be modified to be consistent with the harmonized elements of the GHS. For example, in the US, EPA and OSHA would be expected to require hazard pictograms/symbols on labels. Canada and the EU would be expected to adopt the GHS pictograms/symbols instead of those currently in use. The transport sector is expected to adopt the changed criteria (LD50/LC50) for the GHS Acute Toxicity Categories 1–3. OSHA HCS, WHMIS and the EU would all need to change their acute toxicity criteria.

Test data already generated for the classification of chemicals under existing systems should be accepted when classifying these chemicals under the GHS, thereby avoiding duplicative testing and the unnecessary use of test animals.

GHS labels should be structured like this. You can learn more about the elements (e.g. pictograms, signal words and statements) below.

Existing MSDS symbols have been consolidated into a larger international set of nine pictograms.

Symbol
Means	Unstable explosives Explosives of Divisions 1.1 through 1.4 Self reactive substances and mixtures, types A,B Organic peroxides, types A,B	Flammable gases, category 1 Flammable aerosols, 1 & 2 Flammable liquids, 1,2 & 3 Flammable solids, categories 1,2 Self-reactive substances and mixtures, Types B,C,D,E,F Pyrophoric liquids, category 1 Pyrophoric solids, category 1 Self-heating substances and mixtures, categories 1,2 Substances and mixtures, which in contact with water, emit flammable gases, categories 1,2,3 Organic peroxides, Types B,C,D,E,F	Oxidizing gases, category 1 Oxidizing liquids, categories 1,2,3

Symbol
Means	Gases under pressure: - Compressed gases - Liquefied gases - Refrigerated liquefied gases - Dissolved gases	Corrosive to metals, category 1 Skin corrosion, categories 1A,1B,1C Serious eye damage, category 1	Acute toxicity (oral, dermal, inhalation), categories 1,2,3

Symbol
Means	Acute toxicity (oral, dermal, inhalation), category 4 Skin irritation, category 2 Eye irritation, category 2 Skin sensitisation, category 1 Specific Target Organ Toxicity – Single exposure, category 3	Respiratory sensitization, category 1 Germ cell mutagenicity, categories 1A,1B,2 Carcinogenicity, categories 1A,1B,2 Reproductive toxicity, categories 1A,1B,2 Specific Target Organ Toxicity – Single exposure, categories 1,2 Specific Target Organ Toxicity – Repeated exposure, categories 1,2 Aspiration Hazard, category 1	Hazardous to the aquatic environment - Acute hazard, category1 - Chronic hazard, categories 1,2

Symbols/pictograms for Transport

Flammable Liquid Flammable Gas Flammable Aerosol	Flammable solid Self-Reactive Substances	Pyrophorics (Spontaneously Combustible) Self-Heating Substances
Substances, which in contact with water, emit flammable gases (Dangerous When Wet)	Oxidizing Gases Oxidizing Liquids Oxidizing Solids	Explosive Divisions 1.1, 1.2, 1.3
Explosive Division 1.4	Explosive Division 1.5	Explosive Division 1.6
Compressed Gases	Acute Toxicity (Poison): Oral, Dermal, Inhalation	Corrosive
Marine Pollutant	Organic Peroxides

Symbols/pictograms for Oral Toxicity

ACUTE ORAL TOXICITY - Annex 1
	Category 1	Category 2	Category 3
LD50	£ 5 mg/kg	> 5 < 50 mg/kg	³ 50 < 300 mg/kg
Pictogram
Signal word	Danger	Danger	Danger
Hazard statement	Fatal if swallowed	Fatal if swallowed	Toxic if swallowed

ACUTE ORAL TOXICITY - Annex 1
	Category 4	Category 5
LD50	³ 300 < 2000 mg/kg	³ 2000 < 5000 mg/kg
Pictogram		No symbol
Signal word	Warning	Warning
Hazard statement	Harmful if swallowed	May be harmful if swallowed

The pictogram will be accompanied by either the word:

• Danger for more severe hazards or
• Warning for less severe hazards

Hazard Statements

Hazard statements will appear as an alphanumeric code, beginning with an "H" and followed by three digits.

The first digit will be either:

• 2 for physical hazards
• 3 for health hazards
• 4 for environmental hazards

The subsequent digits provide more specific direction on the nature of the hazard, based on the properties of the substance. The assigned label elements are provided in each hazard chapter of the Purple Book as well as in Annexes 1 & 2. Where there are multiple GHS hazards, there must be an appropriate statement for each one.

Precautionary Statements

Precautionary statements will appear as an alphanumeric code, beginning with a "P" and followed by three digits.

The first digit will be either:

• 1 for general precautionary statements
• 2 for preventative precautionary statements
• 3 for response precautionary statements
• 4 for storage precautionary statements
• 5 for disposal precautionary statements

The subsequent digits provide specific precautionary direction. The assigned label elements are provided in each hazard chapter of the Purple Book as well as in Annexes 1 & 2.

The MSDS provides comprehensive hazard and precaution information for workplace chemical management. It is product-related and not usually able to provide workplace-specific information. However it enables employers to develop an active worker and environmental protection program. Information in a MSDS also provides a source of information for other target audiences such as those involved with the transport of dangerous goods, emergency responders, poison centers, those involved with the professional use of pesticides and consumers.

The MSDS should contain 16 headings (Figure 4.14). The GHS MSDS headings, sequence and content are similar to the ISO, EU and ANSI MSDS/SDS requirements, except that the order of sections 2 and 3 have been reversed. The MSDS should provide a clear description of the data used to identify hazards. The figure below outlines the minimum information required in each section.

The revised Purple Book contains guidance on developing a GHS MSDS (Annex 4).

Minimum information for an MSDS

1.	Identification of the substance or mixture and of the supplier	GHS product identifier. Other means of identification. Recommended use of the chemical and restrictions on use. Supplier's details (including name, address, phone number, etc.). Emergency phone number.
2.	Hazards identification	GHS classification of the substance/mixture and any national or regional information. GHS label elements, including precautionary statements. (Hazard symbols may be provided as a graphical reproduction of the symbols in black and white or the name of the symbol, e.g., flame, skull and crossbones.) Other hazards which do not result in classification (e.g., dust explosion hazard) or are not covered by the GHS.
3.	Composition/information on ingredients	Substance Chemical identity. Common name, synonyms, etc. CAS number, EC number, etc. Impurities and stabilizing additives which are themselves classified and which contribute to the classification of the substance. Mixture The chemical identity and concentration or concentration ranges of all ingredients which are hazardous within the meaning of the GHS and are present above their cutoff levels. NOTE: For information on ingredients, the competent authority rules for CBI take priority over the rules for product identification.
4.	First aid measures	Description of necessary measures, subdivided according to the different routes of exposure, i.e., inhalation, skin and eye contact, and ingestion. Most important symptoms/effects, acute and delayed. Indication of immediate medical attention and special treatment needed, if necessary.
5.	Firefighting measures	Suitable (and unsuitable) extinguishing media. Specific hazards arising from the chemical (e.g., nature of any hazardous combustion products). Special protective equipment and precautions for firefighters.
6.	Accidental release measures	Personal precautions, protective equipment and emergency procedures. Environmental precautions. Methods and materials for containment and cleaning up.
7.	Handling and storage	Precautions for safe handling. Conditions for safe storage, including any incompatibilities.
8.	Exposure controls/personal protection.	Control parameters, e.g., occupational exposure limit values or biological limit values. Appropriate engineering controls. Individual protection measures, such as personal protective equipment.
9.	Physical and chemical properties	Appearance (physical state, color, etc.). Odor. Odor threshold. pH. melting point/freezing point. initial boiling point and boiling range. flash point. evaporation rate. flammability (solid, gas). upper/lower flammability or explosive limits. vapor pressure. vapor density. relative density. solubility(ies). partition coefficient: n-octanol/water. autoignition temperature. decomposition temperature.
10.	Stability and reactivity	Chemical stability. Possibility of hazardous reactions. Conditions to avoid (e.g., static discharge, shock or vibration). Incompatible materials. Hazardous decomposition products.
11.	Toxicological information	Concise but complete and comprehensible description of the various toxicological (health) effects and the available data used to identify those effects, including: information on the likely routes of exposure (inhalation, ingestion, skin and eye contact); Symptoms related to the physical, chemical and toxicological characteristics; Delayed and immediate effects and also chronic effects from short- and long-term exposure; Numerical measures of toxicity (such as acute toxicity estimates).
12.	Ecological information	Ecotoxicity (aquatic and terrestrial, where available). Persistence and degradability. Bioaccumulative potential. Mobility in soil. Other adverse effects.
13.	Disposal considerations	Description of waste residues and information on their safe handling and methods of disposal, including the disposal of any contaminated packaging.
14.	Transport information	UN Number. UN Proper shipping name. Transport Hazard class(es). Packing group, if applicable. Marine pollutant (Yes/No). Special precautions which a user needs to be aware of or needs to comply with in connection with transport or conveyance either within or outside their premises.
15.	Regulatory information	Safety, health and environmental regulations specific for the product in question.
16.	Other information including information on preparation and revision of the SDS