From: Kim Gates <kim.gates**At_Symbol_Here**STONYBROOK.EDU>
Subject: Re: [DCHAS-L] GHS third time and I'll get it right.
Date: April 18, 2013 7:40:24 AM EDT
Reply-To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Message-ID: <005701ce3bb7$6e041ba0$4a0c52e0$**At_Symbol_Here**>

The R&S phrases and orange square pictograms are an old system - pre GHS - and will be going away. The new Hazard & Precautionary phrases are the new GHS/OSHA phrases. Manufacturer's have 3 years from the publication date to rewrite their SDSs, so you will see lots of old info for awhile, and the bigger manufacturer's will start to change over first.

The GHS H&P phrases had numbers "H200", "H310", etc. OSHA did not bring those code numbers into the new regulation, but EU did. So, you may see them on SDSs for materials that are sold in Europe. They are helping me enter the info into my SDS db. Don't use those numbers for training, tho. They won't be on all the SDSs and are not part of the OSHA new scheme. It will only lead to confusion in the workers (too much new info & it won't always be available).

I've found this web site very useful during training for classifying chemicals or finding which chemical has a particular hazard code:

As for the categories vs. NFPA. Don't stress about it. It won't be that confusing for the worker. The labels & SDSs won't solely list that (it must be included, tho). Its 1 part of the new scheme. It will be used by the manufacturer to select the signal word & pictogram. Those are the new elements that workers will use and we should concentrate on our training. OSHA will allow the NFPA & HMIS pictograms to be included on the labels & SDS (read the preamble! Mine is color coded & dog-eared). Manufacturer's must understand & embrace the new category numbers. Workers have to understand the new pictograms & hazard statements. NFPA can still continue to be used in labs & other workplaces on labels or areas, but NFPA was never meant to be anything but a quick visual warning as to a chemical's relative risk. It does not give any specific hazard info. WHen they look at a bottle label, workers will see the red diamond with the hazard pictogram & (maybe) the NFPA diamond with the familiar 0-4 numbers. NFPA isn't used by all manufacturer's, so unless your workplace is relabeling all containers, it shouldn't have been the sole info the worker uses for hazard assessment. I'd like to think or workers, especially the lab people, can understand this new system.

Kim Gates
Laboratory Safety Specialist
Environmental Health & Safety
Stony Brook University
Stony Brook, NY 11794-6200
FAX: 631-632-9683
EH&S Web site:

Please note my name and email have changed.

On Wed, Apr 17, 2013 at 6:03 PM, George Walton <g.c.walton**At_Symbol_Here**> wrote:

One issue is confusing me is the interplay of Risk and Safety Phrases (R- and S- Phrases) and Hazard and Precautionary Phrases (H- and P- Phrases.) Within the last 24 hours, we have downloaded MSDSs from large American chemical supply houses. One supplier uses R and S and the other uses H and P. At either the higher technical levels (researchers, etc.) or lower skill levels (former GIs trying to get along), I really don't see the difference.. We have downloaded R and S lists from the UK Health and Safety Executive and H and P lists from Katholieke Universiteit Leuven and made copies for each work area. The HSE list also shows the little orange squares for explosives, oxidisers, flammables, etc.

George Walton

Reactives Management Corporation

1025 Executive Blvd., Suite 101

Chesapeake, VA 23320

Office: 757-436-1033 Fax: 757-548-2808

From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**MED.CORNELL.EDU] On Behalf Of Allen Niemi
Sent: Wednesday, April 17, 2013 4:41 PM
Subject: Re: [DCHAS-L] GHS

Like some others we have not tackled the training yet and I'd be interested in some suggestions on how we would keep the lab workers from finding out about the conflict and becoming confused? Do we say, continue to use the NFPA (or whatever) system and ignore the GHS numbers on the SDS?


On Wed, Apr 17, 2013 at 4:14 PM, Ralph B. Stuart <rstuart**At_Symbol_Here**> wrote:

> How is anyone tackling the issue of NFPA and other ranking numbers for flammability, toxicity, etc. vs GHS?

I gave a presentation on this topic yesterday to other health and safety professionals where this question came up. My answer agreed with Kent that the numbering system within GHS does not have to be directly used by the person working with the chemical, and I would prefer to avoid discussing with lab workers.

This is particularly a problem in labs because the conflict in the numbering system is not only with NFPA; biosafety and laser safety numbering systems go from 1 to 4 in increasing the hazard level, and if we say chemicals go in one direction and other hazards in the other, the audience is likely to become frustrated and confused.

Cent. Cent.

- Ralph

Ralph Stuart CIH
Chemical Hygiene Officer
Department of Environmental Health and Safety
Cornell University


Allen Niemi, PhD
Occupational Safety and Health Services
Room 322 Lakeshore Center
Michigan Technological University
Phone: 906-487-2118
Fax: 906-487-3048

Previous post   |  Top of Page   |   Next post

The content of this page reflects the personal opinion(s) of the author(s) only, not the American Chemical Society, ILPI, Safety Emporium, or any other party. Use of any information on this page is at the reader's own risk. Unauthorized reproduction of these materials is prohibited. Send questions/comments about the archive to
The maintenance and hosting of the DCHAS-L archive is provided through the generous support of Safety Emporium.