May I offer a creative suggestion? Under the National Technology Transfer and Advancement Act, federal agencies are required to consider voluntary consensus standards as appropriate substitutions or enhancement to regulations. It would behoove us to contact the appropriate technical committee of ASTM International( Possibly E34), and begin development of a standard guide or standard practice to address the divergence between NFPA and GHS.
From: "Williams, Mark"
Sent: Feb 18, 2014 6:52 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=E2=80™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
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