From my experience, the effectiveness of GHS labelling and SDS (MSDS) is three prong: Quality control on the content; Education of the users on how to read them and what they mean; and Consistency in terminology and application in regulatory process.
While working in public health, all three came up when responding to questions about cleaning, disinfecting and sanitizing products, especially new green alternative products --the quality of the SDS (MSDS) sheets for several products identified by user was highly variable, requiring follow up with the manufacturer, regulator (Health Canada), and user. Not a trifling health issue when it comes to providing reliable and appropriate cleaning and disinfection in food services, spas, long term care, schools and daycare centres-.And worker safety!
Mary Ellen
Mary Ellen Starodub, M.Sc. - Principal
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MEStarodub Consulting, Health and the Environment
Health Hazards and Product Safety, Regulatory and Environmental Toxicology and Microbiology,
Children's Environmental Health, Infection Prevention and Control, Contaminated Sites,
Risk Analysis-Risk Assessment, Risk Management, and Risk Communication,
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From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**MED.CORNELL.EDU] On Behalf Of Monona Rossol
Sent: November-22-13 2:09 PM
To: DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU
Subject: Re: [DCHAS-L] GHS Busters
I'm confused by what you wrote. Superglue is a cyanoacrylate, not an isocyanate. And since I am now in the process of referring my SEVENTH scenic artist to Mt. Sinai's Occupational Medical Clinic for a disabling isocyanate illness which required hospitalization, I want ANY product containing 1% of this stuff to get the full treatment. Once sensitized, this 1% would be a serious hazard. And the high numbers of ill and disabled workers are why OSHA made the isocyanates a priority this year.
But your point about Superglue getting the full GHS labeling treatment is one I've thought long an hard about. It seems crazy on the face of it to list it's required GHS classification and ACGIH TLV of a monitor-busting 2 ppm. That is, UNTIL you watch jewelers or model makers with their noses inches from a tube for hours, or artists who squirt out whole tubes of the stuff on surfaces.
I think providing the GHS classifications and for Retail (not bulk) products and providing a statement that used as directed, it is not likely that overexposures will occur, would work. But a consumer should KNOW that using it in more creative ways could be a hell of a problem.
Monona Rossol, M.S., M.F.A., Industrial Hygienist
President: Arts, Crafts & Theater Safety, Inc.
Safety Officer: Local USA829, IATSE
New York, NY 10012 212-777-0062
-----Original Message-----
From: Russ Phifer <rphifer**At_Symbol_Here**WCENVIRONMENTAL.COM>
To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Sent: Fri, Nov 22, 2013 10:40 am
Subject: Re: [DCHAS-L] GHS Busters
I have found the inconsistencies in classification to be dramatic. I reviewed an SDS of a urethane hardener mix from a Japanese firm that indicates the material is a GHS 1 for acute toxicity - and lists code H310 for Fatal in Contact with Skin as well as a variety of other classifications for flammability (H225 - 2 hazard) and skin sensitivity (H334 - GHS 1 and H317 - GHS 1). This is the only SDS I've seen on this material, but the available MSDSs for several similar materials don't come close to showing that degree of hazard. As you can imagine, my client is quite hesitant to use the material, although the only hazardous components for toxicity are several isocyanates present in concentrations below 1%. I would think that an SDS for Super Glue would have to have the same type of classification! Hopefully the UN committee will come up with a good mechanism to encourage consistency.
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The lists that are in the Chemwatch article are government lists of chemical classifications/hazards from the Japanese, New Zealand and South Korean governments.
There is another study done by the UN GHS secretariat. They compared the transportation hazards to the EU CLP/GHS hazards, "GHS classification of dangerous goods most commonly carried: comparison between transport classification and EU CLP Regulation".. This paper which is posted on the UN GHS website shows a similar lack of harmonized hazard classifications.
The EU ECHA Classification and Labeling Inventory that records industry GHS hazards also shows the lack of harmonization. For example there are 69 entries for acetone and 119 for toluene.
However, the UN GHS subcommittee is aware of this lack of harmonization. They are looking at approaches to developing a global list that would have harmonized hazard classifications for chemicals.The USA government is chairing the UN working group looking at developing this globally harmonized list of chemicals classified according to the GHS.
I noticed an interesting article at
https://www.swiftpage6.com/speasapage.aspx?X=2Y0RSDXNI9G1KQ0R00YEWW
about the challenge of GHS:
What does GHS stand for?
The Excercise
Chemwatch have undertaken a systematic comparison of GHS classification published by official sources in:
Europe (ECHA)
Japan (NITE)
New Zealand (CCID)
Korea (NIER)
A total of 12,452 Substances were reviewed.
Interestingly there was very little overlap between Substances reviewed by any two Jurisdictions - Korea and New Zealand reviewed 1494 Substances in common.
However, where Substances in common where assigned GHS Classifications, fewer than 8% were in agreement - New Zealand and the European Union agreed on only 75 Substances of 939 Substances.
In summary:
< 8% Harmonisation between any 2 Jurisdictions
< 0.6% Harmonisation between any 3 Jurisdictions
===
I'm not quite sure of what to make of this data. I wonder if anyone on the list has done international comparisons that include the US?
- Ralph
Ralph Stuart CIH
Chemical Hygiene Officer
Department of Environmental Health and Safety
Cornell University
rstuart**At_Symbol_Here**cornell.edu
