I thought we had this discussion a few months ago as the December deadline neared….
OK my 2 cents…..feel free to fire at will….oh and I agree with Ron on the loose comparative between systems.
Anyway, it was my understanding that for workplace labeling, and for that matter, secondary container labeling in the workplace, as long as the labeling does not conflict with or cause confusion between systems it is acceptable. OSHA did not change the general requirements for workplace labeling. Employers have the option to create their own workplace labels, signage etc. If the requirements for HazCom 1994 are met then all is well (or at least compliant) in the HazCom world in regards to communicating the hazard to a worker. Now having said that, YES there will be confusion. YES there already is confusion….and that includes confusion as to where does GHS really apply to us in the USA, i.e. where is it mandatory. Everybody HAS to be trained to recognize these labeling and hazard communication elements, but where/how do we apply it to our work place.
For our small, private college inventory of roughly 3,000 chemicals we have kept our NFPA door/building signage, we have kept our HMIS secondary container labeling AND have added HMIS labeling to (not in place of) incoming containers for the “at a glance” advantage of the “familiar old system”. However, we completed our initial trainings by the deadline and continue to train on GHS familiarization. Yes, the exclamation point is probably one of the more confusing elements because of it’s general “vagueness”.
I imagine that our situation doesn’t apply to everyone. We work with a wide variety of chemicals….but in small quantities. We don’t “manufacture” chemicals to ship out so we don’t have to provide GHS labeling or GHS-SDS to ship out to a consumer with the chemical. However, we do receive chemicals with GHS labeling, and the GHS-SDS and we keep/maintain up-to-date SDS. Unless, or until, NFPA changes their coding/labeling/placarding system we won’t change our door signage because we don’t want a firefighter to come in and wonder what the crazy pictures are all about when they are so familiar with the diamond….not to mention I don’t believe the GHS system relates to how a chemical acts/reacts etc under FIRE conditions like NFPA system is supposed to. Diamonds for fire-fighters, HMIS for secondary containers and supplemental labeling for our workers. GHS for received chemicals and incoming labeled products and HazCom-SDS.
Another personal opinion inserted…..even if the SDS doesn’t have the HMIS or NFPA codes….if you gather up enough SDS for a chemical you can get a rough idea (if you know the HMIS classification system well enough) to make a decent at-a-glance HMIS label….even though the 4-5 SDS that you gathered really DON’T agree on how hazardous the chemical really is!
Anyhoot, I could go on and on about this as I am sure any of us who have been mired in HazCom training AND practical application of the systems can…we all have opinions and they won’t always agree.
Here is a quote from “OSHA BRIEF: Hazard Communication Standard: Labels and Pictograms” under the workplace labels section: (and here is the URL: https://www.osha.gov/Publications/OSHA3636.pdf )
“ If an employer has an in-plant or workplace
system of labeling that meets the requirements
of HazCom 1994, the employer may continue
to use this system in the workplace as long
as this system, in conjunction with other
information immediately available to the
employees, provides the employees with
the information on all of the health and
physical hazards of the hazardous chemical.
This workplace labeling system may include
signs, placards, process sheets, batch tickets,
operating procedures, or other such written
materials to identify hazardous chemicals. Any
of these labeling methods or a combination
thereof may be used instead of a label from the
manufacturer, importer or distributer as long
as the employees have immediate access to
all of the information about the hazards of the
chemical. Workplace labels must be in English..
Other languages may be added to the label if
I have presented several GHS presentations and from my analysis of the degree of hazard, I have equated the exclamation mark would come closer to being a 1 or 2 based on the hazards:
The only one that causes some issues for me is how to quantify "Acute Toxicity" with the modifier (harmful). Key to the numerical value that you would like to utilize, the specific product has to be included in the decision process.
Now, looking at Health Hazard and the terminology used in that category:
Based on the terminology used in this category, I would utilize 3 or 4. Again, the specific product would still have to be considered.
Then, the skull and crossbones, I think that would be a 4.
Lastly, I am not sure that an employer could not utilize some of the components of the NFPA/HMIS system in the warning process. OSHA standards only identify the minimum requirements. If you labeling system contains all of the items prescribed by OSHA, the employer can always opt for a system that exceeds the minimum.
Just a different thought and perspective.
Ron Hopkins, CFEI, CFPS, F-IAFI
Associate Professor (Retired)
Fire and Safety Engineering Technology
123 Redwood Drive
Richmond, KY 40475-8538
From: DCHAS-L Discussion List <dchas-l**At_Symbol_Here**MED.CORNELL.EDU> on behalf of Williams, Mark <Mark.Williams**At_Symbol_Here**TELEDYNEES.COM>
Sent: Tuesday, February 18, 2014 9:52 AM
Subject: [DCHAS-L] GHS Classification vs NFPA/HMIS
Hello DCHAS Members,
I have just given our second GHS Haz Comm training and the discrepancy between the numerical GHS hazard classification system and that of NFPA/HMIS is fresh in my mind.
I regard this as a noteworthy tragedy because having at our disposal an instantly accessible, “visible across the room”, numerically quantified shorthand that gives us a quick reference for degree of hazard is a really good idea, and GHS has sort of put a torpedo in the NFPA/HMIS label without supplying a good alternative.
For the near term we might get away with continuing to use NFPA or HMIS stickers on container labels because the GHS classification categories do not appear there, so potential for confusion might be small, however as workers become increasingly GHS sophisticated, the potential for confusion will increase quickly and become untenable in the very near future. Perhaps it already is. Certainly including NFPA/HMIS on the SDS is a source of confusion.
In a severely limited sense, the GHS pictograms do give a sort of tiered “visible across the room” semi-quantified shorthand to degree of hazard. The exclamation mark could be considered a 4 but it gives no indication of what the hazard is, and the presence of another pictogram could indicate a 3, 2 or 1, but with no further indication of degree of hazard. Extremely deficient!
The ideal solution in my view would be for NFPA and HMIS to withdraw from the fray, and to convert the GHS pictograms to a numerically tiered system by including the classification category at the bottom of each pictogram similar to the DOT label style.. A 4 on the pictogram would take the place of the exclamation mark which would no longer be needed (and wasn’t that good of an idea to start with). The only pictogram that would need to be modified is the chronic toxicity pictogram as all the rest already have room for a number.
Less ideal, only because it unnecessarily introduces another label element, would be for NFPA and HMIS to change their numbering to the GHS system.
Even better would be to consolidate transportation and Haz Comm pictograms which would eliminate another source of confusion. Call me a dreamer J
I am interested in what others think about this issue.
Teledyne Energy Systems, Inc.
38 Loveton Cir.
Sparks, MD 21152
Previous post | Top of Page | Next post