When I was but a wee lad my dad decided to initiate me to the delights of watching football. So, we went to the only public high school in town, the G.H.S. Purple Hurricanes, and I saw my first football game ever. And so, early in my life I learned that G.H.S. meant Gainesville High School. Within a few years though, there were two new public high schools, and GHS wasn’t the only game in town any longer.
Now that I’m an old coot, there’s a different GHS in my life, the Globally Harmonized System. Adoption of GHS recommendations by the USA’s OSHA seems to be dominating the work lives of many safety professionals, especially regarding SDSs (mSDSs) and revised hazard classifications. Rightly so, as hazard communications probably should be accurate, updated, uniform and compliant. But let’s not forget that the UN Committee of Experts has two Subcommittees. One is GHS. And the other is…, all together now, Transport of Dangerous Goods. Did you know that transport regulations served as the first template for GHS discussions, at least those GHS Subcommittee discussions about physical hazards. So, one might expect there to be much a tremendous amount of harmony regarding GHS, both on its own globally, and in comparison to DG regulations. Of course, one or two examples of disharmony might be reasonable, right?
In some countries, GHS labels are allowed to be in different languages, so long as the home country language is in a font larger than the other languages. In some other countries, GHS labels are allowed to be in different languages, so long as the home country language is in a font larger than the other languages. That’s right, there are countries harmonized in this requirement. But now, try to design a label with multiple languages that can be used in these countries. You can’t. If one country’s language is printed larger than the others, then that label can’t be used in the others’ countries. Each country must have its own unique GHS label. Hmmm, seems like some countries have forgotten what the G in GHS is supposed to mean.
At an SCHC (Society for Chemical Hazard Communication) meeting, a presenter was asked about the prospects for American (North, Central, and South) unified label requirements. If the question needed to be asked, then perhaps the Western Hemisphere doesn’t quite understand the G in GHS, either.
EC and EEC product label warnings are sometimes prescribed based upon the ingredients and their percentages. This seems a great way to save time and reduce testing expenses, until one discovers that many of these prescribed warnings contradict existing test data. GHS is supposed to generate the same conclusions and warnings globally, based upon the actual properties of the products, as shown by testing. Requiring warnings that don’t match actual product test data, seems to me to be a recipe for global disharmonization.
A material that is toxic in Category 4 under the GHS recommendations, isn’t toxic in any Packing Group under the DG recommendations. The GHS exploding bomb pictogram can apply to materials that are not Class 1 in the DG regulations, such as some 4.1 self-reactive materials. Transport regulations don’t require a corrosive label on materials that are corrosive to eyes, but not corrosive to skin, steel, and aluminium. But GHS does require a corrosive pictogram on a product corrosive only to eyes. So much for GHS sticking to the transport regulations’ definitions.
Of course, transport regulations sometimes ignore their own objective, data-driven, classification definitions in favor of subjective conclusions. Look at the toxicity data for Methanol (UN1230) and/or Mercury (UN2809), and you’ll see what I mean. So, the transport folks shouldn’t be throwing any stones regarding reproducible, global conclusions based on the actual properties of products. And, of course, this means that generators of SDSs for Methanol and Mercury might not be communicating the same hazards that are communicated in transport. This isn’t the fault of the GHS Subcommittee, but it is still disharmonization.
Finally, at least for this month’s musings from my porch swing, there are Environmentally Hazardous Substances and Marine Pollutants to consider. May I just say that the variety of lists and of different definitions is a living nightmare. We even use ecotox data for fresh water organisms to determine if a material is a Marine Pollutant. Marine means salt water, not fresh water.
Some of us cynical old coots have a new expression. ‘GHS ain’t Global, and it ain’t Harmonized’. Perhaps Purple Hurricanes isn’t such a bad mascot for GHS after all.
Written 3/3/2014 for HCB Magazine